EMMA Official Statement
NEW ISSUE – BOOK ENTRY ONLY RATINGS: Moody’s (2020 Bonds): Aaa Long Term Standard & Poor’s (2020C-1 Bonds): AAA Short Term Standard & Poor’s (2020C-2 Bonds): A-1+ See “Ratings” herein. In the opinion of Orrick, Herrington & Sutcliffe LLP, Bond Counsel to the District, based upon an analysis of existing laws, regulations, rulings and court decisions, and assuming, among other matters, the accuracy of certain representations and compliance with certain covenants, interest on the 2020C-1 Bonds is excluded from gross income for federal income tax purposes under Section 103 of the Internal Revenue Code of 1986. In the further opinion of Bond Counsel, interest on the 2020C-1 Bonds is not a specific preference item for purposes of the federal alternative minimum tax. Bond Counsel is also of the opinion that interest on the 2020 Bonds is exempt from State of California personal income taxes. Bond Counsel further observes that interest on the 2020C-2 Bonds is not excluded from gross income for federal income tax purposes under Section 103 of the Code. Bond Counsel expresses no opinion regarding any other tax consequences related to the ownership or disposition of, or the amount, accrual or receipt of interest on, the 2020 Bonds. See “TAX MATTERS.” $700,000,000 SAN FRANCISCO BAY AREA RAPID TRANSIT DISTRICT GENERAL OBLIGATION BONDS $625,005,000 $74,995,000 (ELECTION OF 2016), (ELECTION OF 2016), 2020 SERIES C-1 2020 SERIES C-2 (FEDERALLY TAXABLE) (GREEN BONDS) (GREEN BONDS) Dated: Date of Delivery Due: As shown on inside cover The San Francisco Bay Area Rapid Transit District General Obligation Bonds (Election of 2016), 2020 Series C-1 (Green Bonds) (the “2020C-1 Bonds”) and 2020 Series C-2 (Federally Taxable) (Green Bonds) (the “2020C-2 Bonds” and, together with the 2020C-1 Bonds, the “2020 Bonds”) are being issued to finance specific acquisition, construction and improvement projects for District facilities approved by the voters and to pay the costs of issuance of the 2020 Bonds.
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