Section 420-E. Exemption from taxation

It is hereby found, determined and
  declared that the creation of the fund  and  the  carrying  out  of  its
  purposes  is  in all respects for the benefit of the people of the state
  of New York and  for  the  improvement  of  their  health,  welfare  and
  prosperity and is a public purpose, and that the fund will be performing
  an  essential  governmental  function  in  the  exercise  of  the powers
  conferred upon it by this article, and that the fund shall  be  required
  to  pay no fees, taxes or assessments, whether state or local, including
  but not limited to fees, taxes or assessments on real estate,  franchise
  taxes,  sales  taxes  or  other  excise taxes, upon its activities as an
  insurer; and that all income received by the fund and that the bonds  of
  the  fund  and  the  income  therefrom shall at all times be exempt from
  taxation, except for gift and estate taxes and taxes on transfers.  This
  section  shall  constitute  a covenant and agreement with the holders of
  all bonds issued by the fund.