Bobbitt, C.J.
Whether defendant is legally obligated to accept and pay for the three $1,000.00 Series B Bonds is the ultimate question for decision. The answer depends upon whether the validity of the Series B Bonds [582]*582is subject to successful challenge by defendant on any of the grounds asserted by it.
Defendant’s offer to purchase was made with full knowledge of the provisions of the Bond Resolutions of August 29, 1968, and of August 21, 1969, and of the tripartite contracts referred to therein. Hence, we pass without discussion whether “the operating procedures followed by the Authority” are “in violation of the enabling legislation” as now contended by defendant. Nothing appears to indicate that defendant is adversely affected by “the operating procedures followed by the Authority.”
As stated in Nicholson v. Education Assistance Authority, 275 N.C. 439, 448, 168 S.E. 2d 401, 407: “The fact that both parties to an action, as in the present case, desire the determination of the constitutionality of an entire act of the Legislature and stipulate that certain questions, leading to such determination, are presented by the action for the determination of the Court is not binding upon the Court. Such stipulation does not require, or authorize, the Court to pass upon the constitutional questions not necessary to the determination of the right of the party who denies the validity of the legislation.” (Our italics.)
Three basic constitutional questions are presented, viz.:
1. Do “student loans” made pursuant to Chapter 1177 constitute a use of public funds for a public purpose?
2. May the General Assembly constitutionally exempt from taxation revenue bonds issued pursuant to Chapter 1177?
3. Does Chapter 1177 provide sufficient legislative standards for making such “student loans?”
The Authority is an agency of the State. Its affairs are governed by a board of directors of seven members, each appointed by the Governor for a prescribed term. G.S. 116-203.
The sole function of the Authority is to facilitate college (and vocational) education of residents of this State at institutions of higher education (and post-secondary business, trade, technical, and other vocational schools). G.S. 116-202. It was authorized to “acquire” from banks or other lending institutions “a contingent interest” not exceeding 80% (100%) of any individual obligation. G.S. 116-206. (Note: The words and figures enclosed by parentheses indicate amendments made by Chapter 955, Session Laws of 1967.) The Authority is empowered, inter alia, “(t)o receive and accept from any federal or private agency, corporation, association or person grants to be expended in accomplishing the objectives of the Authority [583]*583, . G.S. 116-204(6). The Authority is authorized “(t)o make .and enter into all contracts and agreements necessary or incidental to the performance of its duties and the execution of its powers under this act.” G.S. 116-204(4). G.S. 116-209 provides that “(t)he State Treasurer shall be the custodian of the assets of the Authority.”
The facts concerning the status of the Foundation as “a North Carolina nonprofit public educational service corporation” and the membership of its governing board, are set forth sufficiently in the agreed statement of facts.
The 1965 Act which created the Authority provided for an appropriation of $50,000.00 from the Contingency and Emergency Fund. The $50,000.00 so appropriated, together with money obtained from other sources, including grants “from any federal or private agency, corporation, association or person,” (G.S. 116-204(6)) was constituted a trust fund. G.S. 116-209. This trust fund was for use ■“exclusively for the purpose of acquiring contingent or vested interests in obligations” which the Authority was authorized to acquire.
The assets of this trust fund, now referred to as the “Reserve Trust Fund,” were available and used solely or primarily as a guaranty fund in respect of student loans made by banks or other lending institutions through the College Foundation, Inc. (Foundation) and serviced by the Foundation.
Prior to the enactment of Chapter 1177, the Foundation had qualified as an “eligible lender” under the federal statutes. The term “eligible lender” is defined in 20 U.S.C.A. § 1085(g). The student loans it made in behalf of banks or other lending institutions qualified for federal interest subsidy benefits, for federal guaranty benefits and for guaranty benefits provided by the Authority. The nature and extent of these benefits will be discussed in our consideration of loans made to students from the proceeds of sale of the Authority’s Revenue Bonds.
The authority to issue and sell revenue bonds was conferred by Chapter 1177. It was provided that “(b)onds issued under the provisions of this act (Chapter 1177) shall not be deemed to constitute a debt, liability or obligation of the State or of any political subdivision thereof or a pledge of the faith and credit of the State or of any such political subdivision, but shall be payable solely from the revenues and other funds provided therefor.” G.S. 116-209.12. It also provided that revenue bonds issued under its authority “shall at all times be free from taxation by the State or any local unit or political subdivision or other instrumentality of the State, excepting inheritance or gift taxes.” G.S. 116-209.13.
[584]*584Chapter 1177 provides that the Authority shall deposit the proceeds derived from the sale of its revenue bonds to the credit of a trust fund designated “State Education Assistance Authority Loan Fund” (Loan Fund). The Loan Fund is for use by the Authority in making student loans and in acquiring by purchase promissory notes or other legal instruments evidencing student loans made by banks, educational institutions, nonprofit corporations or other lenders. G.S. 116-209.3.
Pursuant to Chapter 1177, the Authority adopted the Bond Resolution of August 29, 1968, which provided for an initial issue of $3,-000,000.00 of Revenue Bonds, Series A, and for additional bonds, “the aggregate principal amount . . . outstanding at any time . . . not (to) exceed Twelve Million, Five Hundred Thousand Dollars ($12,500,000).” The provisions of the Series A Bonds and attached interest coupons are set forth with particularity. The Series A Bonds are dated July 1, 1968, mature July 1, 1988, and bear interest from date at the rate of 5% per annum payable semiannually on the first days of January and July of each year. This Bond Resolution is set forth on Pages 27-100 of the record.
The $3,000,000.00 of Series A Bonds were sold to investors through the Wachovia Bank & Trust Company, which was designated in the Bond Resolution of August 29, 1968, as Fiscal Agent for the Authority, and the proceeds were used, pursuant to the terms of a “Tripartite Contract” dated August 29, 1968, between the Authority, Wachovia Bank & Trust Company and College Foundation, Inc.
The “Tripartite Contract” of August 29, 1968, referred to in the Bond Resolution of that date, provides for the purchase by the Authority from the Foundation of “student obligations,” listed on an attached inventory and evidencing “student loans,” for a total purchase price of $1,900,000.00, “to be paid solely from the proceeds of Series A Bonds.” It also provides for the purchase by the Authority from the Foundation of “additional student obligations,” evidencing “student loans” to be made by the Foundation during the period of twelve months commencing September 1, 1968, “the purchase price of which shall not exceed the lesser of (i) One Million, One Hundred Thousand Dollars ($1,100,000) or (ii) an amount equal to the balance of the proceeds of the Series A Bonds available therefor.” A recital preceding the contractual provisions recites that “the additional student obligations will bear interest at the rate of six percent (6%) per annum.”
The Bond Resolution adopted by the Authority on August 21, 1969, provided for an additional issue of Revenue Bonds, Series B, [585]*585of $1,500,000.00, “on a parity with the Series A Bonds,” consisting of 1,500 bonds of $1,000.00 each, dated July 1, 1969, maturing July 1, 1989, and bearing interest from date at the rate of 5%% Per an_ num, payable semiannually on the first days of January and July of each year. It was provided that, except as to designation (Series B instead of Series A), the amount of the issue, the date, the maturity, and the interest rate, and the change of name from Wachovia Bank & Trust Company to Wachovia Bank & Trust Company, N.A., Series B Bonds were to be in the form prescribed in the Resolution of August 29, 1968, for Series A Bonds.
A “Supplemental Tripartite Contract” of August 21, 1969, between the Authority, the Foundation and Wachovia Bank & Trust Company, N.A., relates specifically to the Series B Bonds. It provides for the purchase by the Authority from the Foundation of “1969-1970 student obligations,” evidencing student loans made by the Foundation during the period of twelve months commencing September 1, 1969, “the purchase price of which shall not exceed the lesser of (i) One Million, Five Hundred Thousand Dollars ($1,500,-000) or (ii) an amount equal to the balance of the proceeds of the Series B Bonds available for the purchase thereof.” The recital in the preamble preceding the • contractual provisions states that the additional funds for student assistance activities are available for loans “to students who are residents of the State of North Carolina and were enrolled in educational institutions on the date such loan was made and bearing interest at the rate of seven percent (7%) per annum . . . .”
In this Court, the parties have filed a supplement (Supplement) to their original agreed statement of facts. This Supplement discloses, inter alia, the following:
The Foundation, acting as “eligible lender” for the Authority., made 5,548 student loans for the period 1968-1969, which the Authority acquired by use of the proceeds from the sale of its Series A Revenue Bonds. The family income of 94% of the students who obtained these loans was $10,000.00 or less.
The Foundation, acting as “eligible lender” for the Authority, has made 2,418 (additional) student loans, which the Authority has acquired or is obligated to acquire by use of the proceeds of sale of its Series B Revenue Bonds. The family income of 90% of the students who obtained these loans is $10,000.00 or less.
All of these student loans qualify for the federal interest subsidy and the federal guaranteed loan program. 20 U.S.C.A. § 1078. The proceeds from the sale of both Series A and Series B Bonds are used [586]*586exclusively to acquire such student loans and to provide for the expenses of issuing the bonds.
In respect of a student loan, including all of those referred to above, which qualifies as a “Guaranteed Student Loan,” the federal assistance is twofold:
1. INTEREST SUBSIDY. As to loans made prior to June,. 1969, which were financed with the proceeds from the sale of the-Series A Bonds, the Federal Government pays 6% interest thereon plus an administrative fee of 1%. As to loans made subsequent to-June 1, 1969, financed with the proceeds from the sale of the Series B Bonds, the Federal Government pays 7% interest thereon (and more under special circumstances). These payments are made currently. They continue during the entire time the student is in college or vocational school. They exceed the amount necessary to meet, the interest payments on the bonds during the same period.
2. PARTIAL GUARANTEE IN EVENT OF DEFAULT. When a student borrower defaults, the Federal Government pays 80% of the amount in default and 100% in the event of the student’s death or disability. Where default occurs, the remaining 20% of the amount thereof is paid by the Authority from its Reserve-Trust Fund which, as of April, 1970, had assets of $923,657.00. These assets were held, as provided by the 1965 Act, by the State Treasurer.
The Fiscal Agent, under the tripartite contracts, acts as agent off the Authority with reference to the issuance and sale of the bonds, the receipt and disbursement (as directed) of proceeds from bond sales, and the receipt and disbursement of the funds in a Sinking Fund established for payment of the bonds. The assets of the Sinking Fund include all receipts made on account of student loans from the Federal Government, the student borrower and the Reserve Trust Fund.
Additional factual data will be set forth in connection with our consideration of specific legal questions.
Chapter 1177 is valid if and only if the purpose for which the proceeds from the sale of the bonds is authorized and required is adjudged a public purpose.
Section 1, Article IX, of the Constitution of North Carolina, provides: “Religion, morality, and knowledge being necessary to good government and the happiness of mankind, schools and the means of education shall forever be encouraged.” Section 2 contains a mandate that the General Assembly provide for a State [587]*587public school system. Section 3 contains a mandate that the board of commissioners of each county in the State provide the funds for the buildings and equipment necessary for the maintenance and operation of schools within the county for the constitutional term. Constantian v. Anson County, 244 N.C. 221, 225, 93 S.E. 2d 163, 166; Harris v. Board of Commissioners, 274 N.C. 343, 163 S.E. 2d 387, and cases cited. Section 6 provides for the maintenance by the General Assembly of the University of North Carolina; and Section 7 provides that “the benefits of the University, as far as practicable, be extended to the youth of the State free of expense for tuition . . . .” Unquestionably, the education of residents of this State is a recognized object of State government. Hence, provision therefor is for a public purpose. Green v. Kitchin, 229 N.C. 450, 455, 50 S.E. 2d 545, 549; Jamison v. Charlotte, 239 N.C. 682, 696, 80 S.E. 2d 904, 914.
In Clayton v. Kervick, 244 A. 2d 281 (N.J. 1968), the action was for a declaratory judgment in respect of the New Jersey Educational Facilities Authority. The statute which created the Authority declared it to be “a public body corporate and politic” and an instrumentality exercising “public and essential governmental functions.” The Authority was authorized to issue revenue bonds for the construction of facilities, e.g., dormitories, for lease by participating institutions of higher education. In sustaining the constitutionality of the statute, the court stated that the cited constitutional provisions “were designed to insure that public money would be raised and used only for public purpose”; and “(t)hat the furtherance of higher education is a proper public purpose is beyond dispute.” Id. at 290.
13] Subject to constitutional limitations, methods to facilitate and achieve the public purpose of providing for the education or training of residents of this State in institutions of higher education or post-secondary schools are for determination by the General Assembly.
]1] The people of North Carolina constitute our State’s greatest resource. The agreed facts disclose that bond proceeds are to be used solely to make loans to meritorious North Carolinians of slender means and thereby minimize the number of qualified persons whose education or training is interrupted or abandoned for lack of funds. In our view, and we so hold, the bond proceeds are used for a public purpose when used to make such loans.
Of course, it is expected that a student loan will inure to the private benefit of the person who obtains it. It is equally true that the education provided throughout our entire school system is in[588]*588tended to inure to the benefit of the individual who obtains it. However, the fact that the individual obtains a private benefit cannot be considered sufficient ground to defeat the execution of “a paramount public purpose.” Clayton v. Kervick, supra, at 290.
The proceeds from the sale of the Series B Bonds have been used for or are committed to the purchase of specific student obligations representing loans heretofore made by the Foundation. Questions as to the identity of the persons to whom the loans were made or the identity of the institutions they attend are not raised and in any event do not adversely affect defendant.
The student loans authorized thereby being for a public purpose, we hold that Chapter 1177 does not unconstitutionally authorize use of public funds in violation of Section 3, Article V, or of Section 17, Article I, or of Section 7, Article I, of the Constitution of North Carolina, or of Section 1 of the Fourteenth Amendment to the Constitution of the United States.
The parties present for decision whether the provisions of Chapter 1177 which exempt Authority’s revenue bonds from taxation contravene Section 5, Article V, of the Constitution of North Carolina. Section 5, Article V, provides that “(p)roperty belonging to the State or to municipal corporations shall be exempt from taxation” and enumerates other properties the General Assembly may exempt from taxation. The enumerated properties do not include bonds issued by the State or any State agency, whether revenue bonds or full faith and credit bonds.
In Webb v. Port Commission, 205 N.C. 663, 172 S.E. 377, this Court considered the same question in connection with revenue bonds issued for a public purpose by the Port Commission of Morehead City. With reference thereto, the Court said: “The provision in the act by which the Port Commission was created that its property and the bonds that may be issued and sold as authorized by the act shall be exempt from taxation by the State, or any of its political subdivisions, is valid. The General Assembly has the power to so provide, for the reason that the property of the Port Commission will be held, and the bonds will be issued solely for public purposes. Whatever doubt there may be as to the validity of this provision, by reason of section 3 of Article V of the Constitution of this State, must be, under well-settled principles of constitutional construction, resolved in favor of its validity.”
“It is generally considered that the legislature of a state has the power to exempt state and municipal bonds from taxation, since if such bonds are exempt from taxation the state or municipality will [589]*589be able to issue them on more favorable terms and may then save more money than it would lose by being deprived of the right to tax them. The legislature may exempt such securities from taxation, although the constitution enumerates the subjects of exemption, and does not specifically name government securities, and even in the face of a constitutional declaration forbidding passage of laws exempting ‘any property.’ ” 51 Am. Jur. Taxation § 567, p. 558. Since the tax-exempt feature makes possible a more favorable sale of revenue bonds and thereby 'contributes substantially to the accomplishment of the public purpose for which they are issued, we hold that the General Assembly may exempt them from taxation by the State or any of its subdivisions.
In accord with Webb v. Port Commission, supra, we hold that the provisions of Chapter 1177 which exempt the student loan revenue bonds from taxation do not violate Section 5, Article V, of the Constitution of North Carolina.
Defendant contends the provisions of Chapter 1177, which purport to authorize the Authority to make or purchase “student loans” are violative of Section 8, Article I, and of Section 1, Article II, of the Constitution of North Carolina.
Section 8, Article I, provides: “The legislative, executive, and supreme judicial powers of the government ought to be forever separate and distinct from each other.” Section 1, Article II, provides: “The legislative authority shall- be vested in two distinct branches, both dependent on the people, to wit: A Senate and a House of Representatives.” The question is whether, in respect of determining to whom student loans should be made, the General Assembly delegated its legislative authority without providing sufficient standards for a guide.
“It is settled and fundamental in our law that the legislature may not abdicate its power to make laws nor delegate its supreme legislative power to any other coordinate branch or to any agency which it may create. Coastal Highway v. Turnpike Authority, 237 N.C. 52, 74 S.E. 2d 310. It is equally well settled that, as to some specific subject matter, it may delegate a limited portion of its legislative power to an administrative agency if it prescribes the standards under which the agency is to exercise the delegated powers.” Turnpike Authority v. Pine Island, 265 N.C. 109, 114, 143 S.E. 2d 319, 323, and cases cited.
G.S. 116-209.2 provides: “As used in this act, the term ‘eligible institution’ shall' have the same meaning as the definition of such term in section 996 and section 1085 of Title 20 of the United States [590]*590Code and the term ‘student loan’ shall mean loans to residents of this State to enable them to obtain an education in an eligible institution.” 20 U.S.C.A. § 1085(a) provides: “The term ‘eligible institution’ means (1) an institution of higher education, (2) a vocational school, or (3) with respect to students who are nationals of the United States, an institution outside the States which is comparable to an institution of higher education or to a vocational school and which has been approved by the Commissioner for purposes of this part.” 20 U.S.C.A. § 996(a), which has been repealed (88 Stat. 1084), contained a definition of “eligible institution” which was not in conflict with that prescribed in § 1085(a).
Chapter 1177 authorizes the Authority "to develop and administer programs and perform all functions necessary or convenient ... for qualifying for loans, grants, insurance and other benefits and assistance under any program of the United States now or hereafter authorized fostering student loans.” G.S. 116-209.3. The Authority was authorized “to contract with the United States of America or any agency or officer thereof . . . respecting the carrying out of the Authority’s functions under this act.” G.S. 116-209.6. These provisions disclose the General Assembly was well aware of the federal, State and private programs of low-interest insured loans to students in institutions of higher education and other post-secondary schools.
Pertinent provisions of the federal statutes are set forth in summary or verbatim below.
The declared purpose of the federal legislation is to enable the Commissioner of Education “(1) to encourage States and nonprofit private institutions and organizations to establish adequate loan insurance programs for students in eligible institutions (as defined in section 1085 of this title), ... (3) to pay a portion of the interest on loans to qualified students which are made by a State under a direct loan program meeting the requirements of section 1078-(a) (1) (B) of this title, or which are insured under this part or under a program of a State or of a nonprofit private institution or organization which meets the requirements of section 1078(a)(1)(C) of this title, and (4) to guarantee a portion of each loan insured under a program of a State or of a nonprofit private institution or organization which meets the requirements of section 1078(a)(1)(C) of this title.” 20 U.S.C.A. § 1071(a).
To qualify for the federal assistance, consisting of (1) interest subsidy and (2) partial guaranty in the event of default, as set forth above, the “adjusted family income” of the student-borrower must [591]*591be "less than $15,000.00 at the time of execution of the note or written agreement evidencing such loan.”'20 U.S.C.A. § 1078(a)(1)(C). The total of the loans made to a student in any academic year may not exceed $1,500.00. The aggregate insured unpaid principal amount of all such insured loans made to any student shall not at any time exceed $7,500.00. 20 U.S.C.A. § 1075(a).
A loan by an eligible lender is insurable “only if'— (1) made to a student who (A) has been accepted for enrollment at an eligible institution or, in the case of a student already attending such institution, is in good standing there as determined by the institution, and (B) is carrying at least one-half of the normal full-time workload as determined by the institution, and (C) has provided the lender with a statement of the institution which sets forth a schedule of the tuition and fees applicable to that student and its estimate of the cost of board and room for such a student . . .” 20 U.S.C.A. § 1077(a). § 1077(a)(2) sets out in detail the content of “a note or other written agreement” evidencing an insurable student loan including the times and terms of repayment. Subject to enumerated exceptions, such note is to provide for repayment “of the principal amount of the loan in installments over a period of not less than five years (unless sooner repaid) nor more than ten years beginning not earlier than nine months nor later than one year after the date on which the student ceases to carry at an eligible institution at least one-half of the normal full-time academic workload as determined by the institution . . . .”
The interest rate on an insurable loan may not exceed the maximum prescribed by the Secretary of Health, Education and Welfare. 20 U.S.C.A. § 1077(a)(2)(D). The Secretary cannot prescribe a maximum interest rate in excess of 7% on the unpaid principal balance of the loan. 20 U.S.C.A. 1077(b).
The foregoing indicates clearly that Congress has established sufficient standards in respect of loans that qualify for the interest subsidy and for the 80% insurance or guaranty. The agreed statement of facts (Supplement) discloses that all loans made and to be made from the proceeds of the sale of bonds are qualified for the federal assistance.
Persons who obtain “student loans” are unable to make payment on account of interest or principal until completion of their education by graduation or otherwise. The assistance of the Federal Government and coordination with its program are prerequisite to the functioning of the North Carolina student loan program:
[592]*592Although not set forth in express terms, we think it implicit in the provisions of Chapter 1177, that the General Assembly contemplated and intended that no loans would be made from the proceeds from the sale of tax-exempt revenue bonds except student loans made in compliance with the standards prescribed by the federal legislation and therefore qualified for the federal assistance referred to above. Seemingly, the General Assembly realized that its specification of more precise standards for “student loans” might impede the functioning of the Authority and render it unable to qualify from time to time for the federal assistance upon which its program depended.
We are of the opinion, and so hold, that the only student loans the Authority is authorized to make or purchase are student loans which qualify under the federal statutes for federal assistance in respect of interest subsidy and guaranty. When the minimum standards prescribed by Chapter 1177 (G.S. 116-209.2), to wit, “loans to residents of this State to enable them to obtain an education in an eligible institution,” are supplemented by the standards prescribed by the federal legislation, the legislative standards are sufficient. “To construe the statute otherwise would raise a serious question as to its constitutionality; and it is well settled that a statute will not be construed so as to raise such question if a different construction, which will avoid the question of constitutionality, is reasonable.” Milk Commission v. Food Stores, 270 N.C. 323, 331, 154 S.E. 2d 548, 555.
Whether the North Carolina student loan program is wise or unwise is for determination by the General Assembly. Whether the tax-exempt revenue bonds should be approved for investment by fiduciaries and for deposit “for any purpose for which the deposit of bonds or obligations of the State is now or may hereafter be authorized by law,” G.S. 116-209.10, is for determination by the General Assembly. Whether the purchase of these bonds is wise or unwise is for determination by the investor. Our function relates solely to the validity of the Series B Bonds.
Having determined that Chapter 1177 does not violate any of the provisions of the State or Federal Constitutions referred to in the questions posed by the parties in the agreed statement, the judgment of the court below is affirmed.
Affirmed.