§ 657. Tax exemption of corporation. 1. The property, income,
obligations and activities of the corporation shall be exempt from all
taxes and assessments.

2. The state of New York does hereby pledge to and agree with the
holders of the bonds, notes, or other obligations of the corporation
pursuant to this article, or of the state of New York mortgage agency
authorized in section two thousand four hundred six of the public
authorities law for the corporate purposes authorized in section two
thousand four hundred five-a of the public authorities law, or of any
other state entity authorized to issue bonds or notes under the New York
education loan program codified in part V of this article that are
issued for such purpose, and with the holders of such education loans,
that the provisions of law applicable to the New York education loan
program variable rate default reserve fund, the New York education loan
program fixed rate default reserve fund, or the state of New York
mortgage agency New York education loan program default reserve fund, as
applicable, and to the powers of the corporation to receive and deposit
in each such fund the applicable amounts described therein shall not be
amended in a manner adversely affecting the interests of such holders
without adequate provision being made to protect such interests and that
the corporation shall not be required to pay any taxes or assessments
upon any of its property or upon its activities pursuant to the
provisions of this article, or upon any moneys, funds, revenues or other
income held or received by the corporation, and that the obligations and
notes of the corporation and the income therefrom shall at all times be
exempt from taxation, except for estate and gift taxes and taxes on
transfers. Each of the corporation, the state of New York mortgage
agency and any such other public benefit corporation, is authorized to
include this pledge and agreement of the state in any agreements with
the holders of such bonds and with the holders of such education loans.