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There is no mention of the EPA's possible litigation and/or fines against the City in the bond prospectus. If City officials knew of the EPA's 6 findings of violations and failed to disclose these in the prospectus and to advise the bond underwriter and rating agencies accordingly, Bernie Madoff's residence hall may have a few new inhabitants. Furthermore, an interest rate over 5% for tax-exempt 30-year bonds doesn't strike me as any bargain for the city in this interest-rate environment. 30-year fixed-rate mortgages go for that these days and they're taxable!
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