NY Local Government & Property Tax

7/31/2019 NY Local Government & Property Tax

http://slidepdf.com/reader/full/ny-local-government-property-tax 1/10

SPECIAL COMMENT

U.S. PUBLIC FINAMAY 14, 2012

Table of Contents:

SUMMARY OPINION 1 NEW YORK’S PROPERTY TAX CAPMECHANICS AND EXEMPTIONSCHANGE OPERATING ENVIRONMENTFOR LOCAL GOVERNMENTS 2 PENSION RELATED EXEMPTIONS FROMTHE NEW CAP 3 NEW YORK’S TAX CAP IS SIMILAR TOTHOSE IN SOME STATES, DIFFERENTTHAN OTHERS 3 NEW YORK’S LIMITED TAX PLEDGEDEBT WILL NOT BE RATED DIFFERENTLYFROM UNLIMITED 5 PROPERTY TAX CAP TO ADD TO LOCALGOVERNMENT FINANCIAL PRESSURES 5 MOODY’S RELATED RESEARCH 9 Analyst Contacts:

NEW YORK +1.212.553.1653

Robert Weber +1.212.553.7280

Assistant Vice President - Analyst

[email protected]

Geordie Thompson +1.212.553.0321

Vice President - Senior Credit Officer

[email protected]

Naomi Richman +1.212.553.0014

Managing Director - Public Finance

[email protected]

New York Local Governments' Debt UnderNew Property Tax Cap to Be Rated the Sameas Unlimited Tax General Obligation DebtTax Cap Will Pressure New York Local Governments’ Financial Operations

Summary Opinion

Although New York State’s new property tax cap changes the process for raising property taxes to support general obligation debt of local governments (other than school districts), webelieve that the risk profile of debt subject to the cap remains unchanged. However, the cap

will pressure the credit quality of all New York local governments, and could result in areduction of fund balance levels for some. Most vulnerable will be those with reserve levelsalready below average and without the flexibility to offset the new cap.

The new property tax cap, which limits annual property tax levy increases to the lesser of 2%or the rate of inflation, went into effect on January 1, and affects all local governments in thestate; however, school district debt service is exempt.

Based on the terms of the cap and our understanding of how it will operate, we do not

foresee making rating distinctions between the debt subject to the cap, which we refer to ascarrying a “limited tax pledge,” and the same issuers’ unlimited tax pledge because:

» The hurdle to pierce the cap is relatively low.

» The property tax cap law sunsets in 2016.

» The law may be subject to a legal challenge based on a potential conflict with the state

constitution, although none has yet been filed.

If there is a change in the law that increases the difficulty to override the cap, or if the law is extendedbeyond the 2016 sunset date, Moody’s will reassess the affect of the cap on non-school localgovernments to determine if a distinction between unlimited and limited tax debt is warranted.

This report details the credit impact of the property tax law on school districts and on non-

school local governments, by providing:» A review of New York’s property tax cap on local governments, its mechanics and

exemptions.

» A comparison with tax caps in other states.

» An analysis of the credit risk of the limited and unlimited tax pledges, which we believe

are similar under the cap.

» An assessment of the additional financial pressure the new cap will imposed on all New

York local governments.

mailto:[email protected]








U.S. PUBLIC FINANCE

2 MAY 14, 2012 SPECIAL COMMENT: NEW YORK LOCAL GOVERNMENTS' DEBT UNDER NEW PROPERTY TAX CATO BE RATED THE SAME AS UNLIMITED TAX GENERAL OBLIGATION DEBT

New York’s Property Tax Cap Mechanics and Exemptions Change OperatingEnvironment for Local Governments

The property tax cap changes the rules for setting local governments’ property tax rates in New York State. Previously, the property tax rate for every local government was set by the governing body at a

level deemed necessary to fund current year operations (Exhibit 1). For each school district, the boardset the tax levy and then submitted its budget to voters for approval, for which a simple majority wasrequired for passage. If voters did not approve a budget after two attempts, the district would follow acontingency budget, which allowed the district to increase the tax levy up to the lesser of 4% or 120%of the average 12 month CPI, allowing the district to increase the levy to cover a variety of schooloperating expenditures, such as administrative and employee increases, and increases in capitalexpenditures. In some cases, the contingency budget could increase more than the defeated budget.The governing bodies of non-school municipal governments were responsible for setting the levy previously and, with the exception of cities, were not subject to a cap.

The property tax levy raising ability of cities, excluding debt service and certain other purposes, waslimited by the State Constitution to 2% of the five-year average full valuation of taxable real property

within the city. Municipal governments would submit a budget for board approval and a simplemajority of the board would be required for passage.

The new law, which sunsets in 2016, limits local government property tax levy increases to the lowerof 2% or the rate of inflation, and does not allow for contingency budgets with automatic property taxincreases if the budget does not pass. However, there is a mechanism in place to override the cap. Forexample, school districts will continue to need a simple majority of voters to pass their annual budgets,but will need at least 60% voter approval for a levy increase beyond the limit. If voters do not approvea budget , the levy remains at the previous year’s level. The law does provide, however, an exemptionfor school capital expenses, including debt service. Despite this, we believe school districts will facemore overall financial pressure from the cap given the need for voter approval to override it. Non-school municipal budgets are not subject to voter approval in New York, but will require 60%approval of the governing body to increase the tax levy above the cap. Debt service for non-school debtis subject to the cap, including debt issued prior to the law’s effective date (January 1, 2012).

Once a local government has voted to override the cap, it retains that levy the following year. In theevent that a municipality that did not get an approval for an override raises the levy beyond the limit,it may not use those additional funds for operations or debt service. Instead, the municipality mustpromptly place property tax funds in excess of the limit in a reserve fund, which is then credited to thenext year’s levy and incorporated in the cap for that year. Local governments are allowed to carry aportion of unused levy capacity into the subsequent year.



U.S. PUBLIC FINANCE


EXHIBIT 1

New Tax Cap Impedes Local Government’s Ability to Raise Revenues

Before implementation of cap After implementation of cap

School Districts

Requirements forBudget Approval

50% voter approval of budgets,including tax increase

60% voter approval of budgets topierce the cap, 50% voter approval

for budgets that are within cap

Failure of BudgetPassage

Contingency budget after two failedbudget votes may include smallincrease in tax levy

Contingency budget after two failedbudget votes will have their levy lessthan or equal to previous year’s levy

Exemption for DebtService

No limitation on tax increase fordebt service

Debt service exempted from levylimit

Non-School

Local

Governments

Requirements forBudget Approval

50% approval of governing body forbudgets, including tax increase

60% approval of governing body forbudgets that exceed the propertytax increase

Failure of BudgetPassage

Failure of budget passage results inadoption of revised preliminarybudget

Failure of passage results in passage(with revisions) as long as taxincrease is within the limit. If notwithin limit, preliminary budgetwithout increase is reintroduced andfollow above process

Exemption for DebtService

No limitation on tax increase fordebt service

Debt service not exempted fromlimitation.

Pension Related Exemptions from the New Cap

The new law also provides for various additional exemptions, including for tort expenses in excess of 5% and a portion of pension increases. The pension exemption for non-school local governments willbe determined each year by the state comptroller, based on the average cost of pension increases for allemployees that participate in the Employee Retirement System (ERS) and the Police and FireRetirement System (PFRS). For school districts, the normal contribution rate for the Teachers’

Retirement System (TRS) would be used to calculate the increase in pension costs.

There is an exemption for the average statewide increase in these costs that exceed 2%. Although theformula is based on average growth, some municipalities will benefit more than others, depending onthe increases in their individual pension costs. For example, if the statewide average annual growth inpension costs for all employees is 3%, the state would allow all local governments to exempt the cost ofa 1% increase in their individual annual pension contribution. Any municipality with pension growthbelow 1% would still be authorized to exceed the cap to cover the full 1% growth. Conversely, amunicipality with an ERS pension increase above 1% would not be authorized to exceed the cap tocover more than the 1% the state allowed for that year.

New York’s Tax Cap is Similar to Those in Some States, Different than Others

Many U.S. states impose property tax caps that limit a local government’s ability to raise its property tax rate.

These property tax caps have existed in various US states for some time, although they have becomemore prevalent over the past decade as many state governments have looked to curb the growth inlocal government real estate taxes. Property tax caps vary from state to state, ranging from a limitationon all property tax revenues to those on operational levies only, exempting property taxes levied



U.S. PUBLIC FINANCE


specifically for debt service. Many of the tax caps for local governments exempt debt service for debtthat existed at the time of the cap, but there are examples, like New York, where all debt service issubject to the cap. The State of Maine’s property tax cap applies to annual levy growth and does notexempt new debt (although it does exempt debt issued prior to the implementation). The Maine capalso allows for levy growth based on a floating annual index, although there is no maximum growth

limit like the 2% cap in New York; the law also allows for limited exemptions. Maine localgovernments can override the cap with a vote of the town board or city council, as can non-schoolmunicipalities in New York, and many have done so on a regular basis. We treat limited and unlimitedtax debt in Maine the same and do not make a rating distinction.

Pennsylvania school districts are also subject to a statewide property tax cap, although it restrictsannual increases to the tax rate as opposed to the overall levy, allowing for growth in the tax base toincrease the levy. The state sets an index each year by which school districts may increase theirproperty tax rates, based on statewide wage increases and the employment cost index for schools. Debtauthorized before the cap’s effective date in 2006 (and debt refunding such “grandfathered”obligations) is exempt, as is any debt approved by voters (known as electoral debt); all other debt issubject to the cap, resulting in both unlimited and limited tax pledges.

Like New York school districts, Pennsylvania school districts need the approval of a majority of registered voters to exceed the cap, although this is not common given that school budgets inPennsylvania are not generally subject to voter approval, as they are in New York. We treat limited taxschool district debt in Pennsylvania on a case-by-case basis, assigning ratings that are one notch below unlimited tax ratings based on several factors, including the growth trend in the school district’s taxbase (given the ability to capture new growth in the levy) and a school district’s financial flexibility,including reserves that supplement tax revenues.

The trend of allowable property tax rate increases, based on the annual index, is also a factor in ourassessment. In many cases, these factors are sufficient to mitigate the credit risk of the limited taxpledge. In others, they do not provide sufficient offset to the limited pledge, and hence we assign a

rating with a one-notch distinction from the unlimited tax pledge. The fundamental differencesbetween the Pennsylvania limited tax pledge on school districts and the New York non-school limitedtax pledge is the relative ease of New York municipalities to override the cap and the sunset provisionin the law.

Rating Impact Depends on Restrictiveness of Tax Cap

When debt is subject to a property tax cap, we assess the effect of the limitation on local governments’financial operations. In some states, some or all debt service obligations are subject to the cap, as is thecase for non-school debt in New York. When that is the case, in addition to our assessment of thecap’s effect on local government financial operations, we also assess to what extent the limitation onthe general obligation pledge increases the credit risk to bondholders. Our assessments are generally based on the strictness of the cap, the ability and mechanism for exceeding it, and the localgovernment’s ability to increase the levy based on tax base growth.

In some states, we rate the limited pledge lower than the unlimited pledge, usually by one notch. Thisis the case in Washington State, for instance, where local governments are able to issue both unlimitedand limited tax debt. In other states, such as Massachusetts, we have concluded that the limitation onthe pledge does not materially increase credit risk and we do not have a rating distinction. In still



U.S. PUBLIC FINANCE


other cases, such as Pennsylvania school districts, we assess limited tax debt on a case-by-case basis, andsometimes distinguish between the two ratings.

New York’s Limited Tax Pledge Debt Will Not Be Rated Differently from

Unlimited

Consistent with our treatment of limited tax debt in other states, we do not believe that the new limited tax pledge for non-school debt, in and of itself, creates sufficient additional credit risk relativeto the unlimited tax pledge to warrant a rating distinction. The threshold for non-school localgovernments to override the cap, namely a 60% vote of the governing body, is relatively manageable,especially for those municipalities with small governing entities. For example, many municipalities inNew York have five-member boards, so the simple majority needed to pass a budget wouldautomatically result in an override for these local governments. Even for municipalities where theboard is composed of more than five members, we believe that generally, local governments will notface significant challenges overriding the cap in order to meet their obligations, including debt service.Moreover, a failure to override the cap could put pressure on financial operations, affecting the credit

of both unlimited and limited tax debt.

In addition to the relative ease of exceeding the cap, the law sunsets in 2016, and there will likely be adebate in the state legislature as to whether to extend the law at that time. If the cap does lapse in2016, the general obligation pledge of non-school local governments will revert to unlimited tax.Should the cap be extended in perpetuity or for a significant duration, we will revisit its treatment of limited tax debt issued by New York local governments.

The question of the law’s constitutionality has been raised by various market participants in New York, including several bond counsels, who have indicated that law may not prevent a localgovernment from raising property taxes beyond the cap in order to meet general obligation debtservice. Their reasoning is based on the language in Article 8, Section 12 of the New York State

Constitution, which states: “The legislature shall not, however, restrict the power to levy taxes on realestate for the payment of interest on or principal of indebtedness theretofore contracted.” In addition,the New York State Court of Appeals, the highest court in the state, ruled in the 1976 FlushingNational Bank case that “…the pledge of faith and credit, expresses a constitutional imperative: debtservice must be paid, even if tax limits be exceeded.” While we believe the potential for a legalchallenge exists, we are not aware of any lawsuits that are currently pending. We will monitor any suchchallenges to the law and reassess the impact of any court rulings that pertain to it.

Property Tax Cap to Add to Local Government Financial Pressures

The property tax cap will increase the financial pressures of all New York local governments, whocurrently face a challenging operating environment that affects both unlimited and limited tax debt. New

York local governments, like their counterparts in many other states, continue to confront growth infixed costs related to pensions and healthcare expenditures, education and public safety costs.

Additionally, revenues remain weak, there has been limited growth in sales and income tax receipts, stateaid, and other non-property tax revenues. As stated above, we believe school districts are likely to be mostaffected by the cap, although non-school local governments will face additional pressure as well.

The initial budget vote for school districts in the state is set for May 15. Of the state’s 669 schooldistricts, 51 are seeking to override the new property tax cap. School districts that are unable to pass



U.S. PUBLIC FINANCE


their budgets will have a second chance to do so with the risk of losing the ability to increase the levy at all if they fail to pass the budget on the second try . Failure to pass a budget would also result inlosing the handful of exemptions allowed under the law.

The new cap is likely to affect individual school districts differently, depending on the economic,

political, or legal environment within which each school district functions. For example, a new law inNassau County, NY (A1 negative) taking effect in the coming fiscal year, will make school districtsresponsible for refunding payments from the county for tax certioraris, which will be the first time they

will be required to do so in more than 70 years. Prior to this law, the county insured the collection of property taxes for all local governments without requiring reimbursement in subsequent years. Thenew law requires that school districts reimburse the county for lost revenue, which represents asignificant new pressure for Nassau County districts given that payments for tax certioraris are notexempt from the property tax cap. The county law is currently being challenged in state court.

New York counties, as well as a number of cities and towns, were the first local governments to be subjectto the tax cap, given fiscal years that begin January 1. Many voted to override the property tax cap and, insome cases, significantly increased property taxes. Among the 56 New York counties (not including the 5

New York City counties), 12 approved overrides of which some raised taxes by a significant margin abovethe cap. For example, Rockland County (Baa3 negative) passed a 31% property tax increase in order toclose a growing budget gap and repay an $18 million deficiency note issued in 2011.

Some local governments exceeded the cap without securing an override, and in keeping with the law,the state is requiring them to place the excess revenue in a reserve fund as a credit against next year’slevy. Those that stayed within the levy limit generally focused on expense-side solutions to closebudget gaps, including layoffs, hiring and salary freezes, overtime reductions, amortization of pensioncontributions, and some benefit changes. Others have reported delays in capital projects andreductions in pay-go capital spending.

As Exhibit 2 indicates, local government reserve levels have been relatively stable, on average, and have

even increased in some cases, evidence of the generally conservative budgeting typical of localgovernment financial operations in New York. We expect financial pressures to be exacerbated by thetax cap and potentially result in a reduction of fund balance levels going forward. Most vulnerable willbe those local governments with reserve levels that are already below average and do not have thefinancial flexibility to offset the limitations of the tax cap (Exhibit 3).



U.S. PUBLIC FINANCE


EXHIBIT 2

General Fund Balances Have Been Stable Over Past Six Years

*data for 2011 is statistically insignificant at this time.

Source: Moody’s Municipal Financial Ratio Analysis (MFRA)

We expect that local governments in the state will continue to budget for all of their obligations,including debt service, and manage their budgets accordingly, but they will also continue to facepressure from their constituencies not to override the cap.

EXHIBIT 3

Municipalities with Low Reserve Levels Face Greatest Pressure New York Municipalities with Low Fund Balance

Obligor Rating

General FundBalance as % of

Revenues Obligor Rating


Revenues

Amityville Village, NY A2 -2.6 North Greenbush Town, NY A2 -2.1

Arcade Village, NY A3 3.8 Oyster Bay Town, NY Aa3 2.3Babylon Village, NY A1 1.8 Poughkeepsie Town, NY A1 1

Bayville Village, NY A1 -1.9 Poughkeepsie City, NY A2 -13.7

Broome County, NY A2 2.2 Rockland County, NY Baa3 -0.9

Colonie Town, NY Baa1 -35.9 Roslyn Village, NY A2 1.1

East Greenbush Town, NY Ba1 -22.7 Saugerties Central School District (UlsterCounty), NY

A2 3.2

East Hampton Town, NY A1 -8.4 Seaford School District (Nassau County), NY A1 4.6

Endicott Village, NY Baa1 2.1 Solvay Village, NY Baa1 2.2

Fishkill Town, NY Baa3 -46 Southeast Town, NY Aa3 1.8

Glen Cove City, NY Baa3 -5.9 Suffern Village, NY A2 1.8

Hamburg Central School District (ErieCounty), NY

A1 4.6 Suffolk County, NY A1 -6.1

Harrison Village, NY Aa3 -1.4 Ticonderoga Central School District (EssexCounty), NY

A1 4.9

Hastings-On-Hudson Village, NY Aa3 3.1 Utica City, NY A3 3.7

Lockport City, NY A2 2.9 Wappingers Central School District(Dutchess County), NY

A1 4.4



U.S. PUBLIC FINANCE


EXHIBIT 3

Municipalities with Low Reserve Levels Face Greatest Pressure New York Municipalities with Low Fund Balance

Obligor Rating


Revenues Obligor Rating


RevenuesLong Beach City, NY Baa3 3.7 Wyandanch Union Free School District

(Suffolk County), NYBa1 3.4

Monroe County, NY A3 1 Yonkers City, NY Baa1 2.4

Newburgh City, NY Ba1 -9.2

Source: Moodys.com



U.S. PUBLIC FINANCE


Moody’s Related Research

Special Comment:

» New York State’s Property Tax Cap will Further Pressure Local Government Finances; School

Districts Most Impacted, July 2011 (134177)

Outlook:

» Outlook for U.S. Local Governments Remains Negative in 2012, February 2012 (139418)

To access any of these reports, click on the entry above. Note that these references are current as of the date of publication othis report and that more recent reports may be available. All research may not be available to all clients.

http://www.moodys.com/viewresearchdoc.aspx?docid=PBM_PBM134177










U.S. PUBLIC FINANCE


Report Number: 141992

AuthorsGeordie ThompsonRobert Weber

Senior Production AssociateGinger Kipps

© 2012 Moody’s Investors Service, Inc. and/or its licensors and affiliates (collectively, “MOODY’S”). All rights reserved.

CREDIT RATINGS ISSUED BY MOODY'S INVESTORS SERVICE, INC. (“MIS”) AND ITS AFFILIATES ARE MOODY’S CURRENTOPINIONS OF THE RELATIVE FUTURE CREDIT RISK OF ENTITIES, CREDIT COMMITMENTS, OR DEBT OR DEBT-LIKESECURITIES, AND CREDIT RATINGS AND RESEARCH PUBLICATIONS PUBLISHED BY MOODY’S (“MOODY’SPUBLICATIONS”) MAY INCLUDE MOODY’S CURRENT OPINIONS OF THE RELATIVE FUTURE CREDIT RISK OF ENTITIES,CREDIT COMMITMENTS, OR DEBT OR DEBT-LIKE SECURITIES. MOODY’S DEFINES CREDIT RISK AS THE RISK THAT ANENTITY MAY NOT MEET ITS CONTRACTUAL, FINANCIAL OBLIGATIONS AS THEY COME DUE AND ANY ESTIMATEDFINANCIAL LOSS IN THE EVENT OF DEFAULT. CREDIT RATINGS DO NOT ADDRESS ANY OTHER RISK, INCLUDING BUTNOT LIMITED TO: LIQUIDITY RISK, MARKET VALUE RISK, OR PRICE VOLATILITY. CREDIT RATINGS AND MOODY’S

OPINIONS INCLUDED IN MOODY’S PUBLICATIONS ARE NOT STATEMENTS OF CURRENT OR HISTORICAL FACT. CREDITRATINGS AND MOODY’S PUBLICATIONS DO NOT CONSTITUTE OR PROVIDE INVESTMENT OR FINANCIAL ADVICE, ANDCREDIT RATINGS AND MOODY’S PUBLICATIONS ARE NOT AND DO NOT PROVIDE RECOMMENDATIONS TO PURCHASE,SELL, OR HOLD PARTICULAR SECURITIES. NEITHER CREDIT RATINGS NOR MOODY’S PUBLICATIONS COMMENT ON THESUITABILITY OF AN INVESTMENT FOR ANY PARTICULAR INVESTOR. MOODY’S ISSUES ITS CREDIT RATINGS ANDPUBLISHES MOODY’S PUBLICATIONS WITH THE EXPECTATION AND UNDERSTANDING THAT EACH INVESTOR WILLMAKE ITS OWN STUDY AND EVALUATION OF EACH SECURITY THAT IS UNDER CONSIDERATION FOR PURCHASE,HOLDING, OR SALE.

ALL INFORMATION CONTAINED HEREIN IS PROTECTED BY LAW, INCLUDING BUT NOT LIMITED TO, COPYRIGHT LAW, ANDNONE OF SUCH INFORMATION MAY BE COPIED OR OTHERWISE REPRODUCED, REPACKAGED, FURTHER TRANSMITTED,TRANSFERRED, DISSEMINATED, REDISTRIBUTED OR RESOLD, OR STORED FOR SUBSEQUENT USE FOR ANY SUCH PURPOSE, INWHOLE OR IN PART, IN ANY FORM OR MANNER OR BY ANY MEANS WHATSOEVER, BY ANY PERSON WITHOUT MOODY’SPRIOR WRITTEN CONSENT.

All information contained herein is obtained by MOODY’S from sources believed by it to be accurate and reliable. Because of thepossibility of human or mechanical error as well as other factors, however, all information contained herein is provided “AS IS”without warranty of any kind. MOODY'S adopts all necessary measures so that the information it uses in assigning a credit rating is osufficient quality and from sources MOODY'S considers to be reliable including, when appropriate, independent third-party sources.However, MOODY’S is not an auditor an d cannot in every instance independently verify or validate information received in the rating

process. Under no circumstances shall MOODY’S have any liability to any person or entity for (a) any loss or damage in whole or inpart caused by, resulting from, or relating to, any error (negligent or otherwise) or other circumstance or contingency within oroutside the control of MOODY’S or any of its directors, officers, employees or agents in connection with the procurement, collection,compilation, analysis, interpretation, communication, publication or delivery of any such information, or (b) any direct, indirect,special, consequential, compensatory or incidental damages whatsoever (including without limitation, lost profits), even if MOODY’Sis advised in advance of the possibility of such damages, resulting from the use of or inability to use, any such information. Theratings, financial reporting analysis, projections, and other observations, if any, constituting part of the information contained hereinare, and must be construed solely as, statements of opinion and not statements of fact or recommendations to purchase, sell or holdany securities. Each user of the information contained herein must make its own study and evaluation of each security it mayconsider purchasing, holding or selling.

NO WARRANTY, EXPRESS OR IMPLIED, AS TO THE ACCURACY, TIMELINESS, COMPLETENESS, MERCHANTABILITY OR FITNESSFOR ANY PARTICULAR PURPOSE OF ANY SUCH RATING OR OTHER OPINION OR INFORMATION IS GIVEN OR MADE BYMOODY’S IN ANY FORM OR MANNER WHATSOEVER.

MIS, a wholly-owned credit rating agency subsidiary of Moody’s Corporation (“MCO”), hereby discloses that most issuers of debtsecurities (including corporate and municipal bonds, debentures, notes and commercial paper) and preferred stock rated by MIS haveprior to assignment of any rating, agreed to pay to MIS for appraisal and rating services rendered by it fees ranging from $1,500 toapproximately $2,500,000. MCO and MIS also maintain policies and procedures to address the independence of MIS’s ratings andrating processes. Information regarding certain affiliations that may exist between directors of MCO and rated entities, and between

entities who hold ratings from MIS and have also publicly reported to the SEC an ownership interest in MCO of more than 5%, isposted annually at www.moodys.com under the heading “Shareholder Relations — Corporate Governance — Director andShareholder Affiliation Policy.”

Any publication into Australia of this document is by MOODY’S affiliate, Moody’s Investors Service Pty Limited ABN 61 003 399 657which holds Australian Financial Services License no. 336969. This document is intended to be provided only to “wholesale clients”within the meaning of section 761G of the Corporations Act 2001. By continuing to access this document from within Australia, yourepresent to MOODY’S that you are, or are accessing the document as a representative of, a “wholesale client” and that neither younor the entity you represent will directly or indirectly disseminate this document or its contents to “retail clients” within the meaningof section 761G of the Corporations Act 2001.

Notwithstanding the foregoing, credit ratings assigned on and after October 1, 2010 by Moody’s Japan K.K. (“MJKK”) are MJKK’scurrent opinions of the relative future credit risk of entities, credit commitments, or debt or debt-like securities. In such a case, “MIS”in the foregoing statements shall be deemed to be replaced with “MJKK”. MJKK is a wholly-owned credit rating agency subsidiary of Moody's Group Japan G.K., which is wholly owned by Moody’s Overseas Holdings Inc., a wholly-owned subsidiary of MCO.

This credit rating is an opinion as to the creditworthiness of a debt obligation of the issuer, not on the equity securities of the issuer oany form of security that is available to retail investors. It would be dangerous for retail investors to make any investment decisionbased on this credit rating. If in doubt you should contact your financial or other professional adviser.

http://www.moodys.com/




NY Local Government & Property Tax

Documents

Transcript of NY Local Government & Property Tax