This report, prepared by a project subcommittee of the Committee on General Law and Practice (the “Committee”) of the National Association of Bond Lawyers (“NABL”), is intended to assist practitioners when they give “bond opinions,” i.e., letters that contain opinions regarding the validity of, source of payment and security for, and tax status of bonds or other financial obligations of states or their political subdivisions (“municipal bonds”). The Board of Directors of NABL has authorized the distribution of this report.

This report is the fifth edition of NABL’s model bond opinion report. Each report has been designed to reflect then-current municipal bond practice. This report and the model opinion letters included in it are updates of the following earlier reports and model opinion letters: (i) the Model Bond Opinion Project report prepared in 1982 and 1983 by the Committee on Opinions; (ii) the 1987 revision undertaken by the Special Committee on Opinions to reflect changes brought about by the Tax Reform Act of 1986 (the “1987 Report”); (iii) the Statement Concerning Standard Applied in Rendering the Federal Income Tax Portion of Bond Opinions adopted by the Board of Directors of NABL on November 29, 1993 (“Tax Standard”), (iv) the 1997 revision undertaken by the Committee on Opinions; and (v) the 2003 revision (the “2003 Report”) undertaken by the Committee on Opinions and Documents. The 2003 Report was supplemented by a 2009 report (the “2009 Supplemental Report”) prepared by an ad hoc committee to assist practitioners in preparing opinions and other written advice relating to Build America Bonds for which the issuer elected to receive a refundable tax credit, which were referred to in the 2009 Supplemental Report as “Direct Payment BABs.”

Click here to view the fifth edition of NABL’s signature report updated to reflect current municipal bond practices. Tyler Kalachnik was one of the project co-chairs tasked with producing this resource.