Common use of Accounting and Reports to the Noteholders, Certificateholders, the Internal Revenue Service and Others Clause in Contracts

Accounting and Reports to the Noteholders, Certificateholders, the Internal Revenue Service and Others. The Depositor or, if any Trust Certificates are held by any Person other than the Depositor or its Affiliate, the Trustee, shall: (a) maintain (or cause to be maintained) the books of the Trust on a calendar year basis on the accrual method of accounting, (b) deliver to each Certificateholder, as may be required by the Code and applicable Treasury Regulations, such information as may be required (including Schedule K-1, if applicable) to enable each Certificateholder to prepare its federal, State and local income tax returns, (c) file such tax returns relating to the Trust (including, if applicable, a partnership information return on Internal Revenue Service Form 1065 or its successor), and make such elections as may from time to time be required or appropriate under any applicable State or federal statute or rule or regulation thereunder so as to maintain the Trust’s characterization as a disregarded entity or partnership for federal income tax purposes, as applicable, (d) cause such tax returns to be signed in the manner required by law and (e) collect or cause to be collected any withholding tax as described in and in accordance with Section 5.2(c) with respect to income or distributions to Certificateholders. The Trustee shall elect under Section 1278 of the Code to include in income currently any market discount that accrues with respect to the Receivables and shall elect under Section 171 of the Code to amortize any bond premium with respect to the Receivables. The Trustee shall not make the election provided under Section 754 of the Code.

Accounting and Reports to the Noteholders, Certificateholders, the Internal Revenue Service and Others. The Depositor or, if any Trust Certificates are held by any Person other than the Depositor or its Affiliate, the Trustee, shall: Eligible Lender Trustee shall (a) maintain (or cause to be maintained) the books of the Trust on a calendar year basis on the accrual method of accounting, (b) deliver to each Certificateholderholder of the Trust Certificates (and to each Person who was a holder of the Trust Certificates at any time during the applicable calendar year), as may be required by the Code and applicable Treasury Regulations, such information as may be required (including Schedule K-1, if applicable) to enable each Certificateholder such holder of the Trust Certificates to prepare its federal, State Federal and local state income tax returns, (c) file such tax returns relating to the Trust (including, if applicable, including a partnership information return on return, Internal Revenue Service Form 1065 or its successor1065), and make such elections as may from time to time be required or appropriate under any applicable State state or federal Federal statute or rule or regulation thereunder so as to maintain the Trust’s 's characterization as a disregarded entity or partnership for federal Federal income tax purposes, as applicable, (d) cause such tax returns to be signed in the manner required by law and (e) collect or cause to be collected any withholding tax as described in and in accordance with Section 5.2(c5.01(c) with respect to income or distributions to Certificateholdersthe holders of the Trust Certificates. The Eligible Lender Trustee shall elect under Section 1278 of the Code to include in income currently any market discount that accrues with respect to the Receivables and shall elect under Section 171 of the Code to amortize any bond premium with respect to the ReceivablesFinanced Student Loans. The Eligible Lender Trustee shall not make the election provided under Section 754 of the Code.

Accounting and Reports to the Noteholders, Certificateholders, the Internal Revenue Service and Others. The Depositor or, if any Trust Certificates are held by any Person other than the Depositor or its AffiliateSubject to Section 2.6, the Trustee, shall: Administrator shall (a) maintain (or cause to be maintained) the books of the Trust on a calendar year basis on the accrual method of accounting, (b) deliver (or cause to be delivered) to each CertificateholderResidual Interestholder, as may be required by the Code and applicable Treasury Regulations, such information as may be required (including Schedule K-1, if applicable) to enable each Certificateholder Residual Interestholder to prepare its federal, State federal and local state income tax returns, (c) prepare and file such tax returns relating to the Trust (includingincluding a partnership information return, Form 1065, if applicable, a partnership information return on Internal Revenue Service Form 1065 or its successor), and make such elections as may from time to time be required or appropriate under any applicable State state or federal statute or rule or regulation thereunder so as to maintain the Trust’s 's characterization as a disregarded entity or partnership for federal income tax purposes, as applicable, (d) cause such tax returns to be signed in the manner required by law and (e) collect or cause to be collected any withholding tax as described in and in accordance with Section 5.2(c) with respect to income or distributions to CertificateholdersResidual Interestholders. The Owner Trustee shall cooperate with the Administrator in making all elections pursuant to this Section as directed in writing by the Administrator. The Trust shall elect under Section 1278 of the Code to include in income currently any market discount that accrues with respect to the Receivables and shall elect under Section 171 of the Code to amortize any bond premium with respect to the Receivables. The Trustee Trust shall not make the election provided under Section 754 of the Code.

Accounting and Reports to the Noteholders, Certificateholders, the Internal Revenue Service and Others. The Depositor or, if any Trust Certificates are held by any Person other than the Depositor or its Affiliate, the Trustee, shall: Eligible Lender Trustee shall (a) maintain (or cause to be maintained) the books of the Trust on a calendar year basis on the accrual method of accounting, (b) deliver (or cause to be delivered) to each CertificateholderCertificateholder (and to each Person who was a Certificateholder at any time during the applicable calendar year), as may be required by the Code and applicable Treasury Regulations, such information as may be required (including Schedule K-1, if applicable) to enable each such Certificateholder to prepare its federal, State Federal and local state income tax returns, (c) file (or cause to be filed) such tax returns relating to the Trust (including, if applicable, including a partnership information return on return, Internal Revenue Service Form 1065 or its successor1065), and make such elections as may from time to time be required or appropriate under any applicable State state or federal Federal statute or rule or regulation thereunder so as to maintain the Trust’s 's characterization as a disregarded entity or partnership for federal Federal income tax purposes, as applicable, (d) cause such tax returns to be signed in the manner required by law and (e) collect (or cause to be collected collected) any withholding tax as described in and in accordance with Section 5.2(c5.1(c) with respect to income or distributions to Certificateholders. The Eligible Lender Trustee shall elect under Section 1278 of the Code to include in income currently any market discount that accrues with respect to the Receivables and shall elect under Section 171 of the Code to amortize any bond premium with respect to the ReceivablesTrust Student Loans. The Eligible Lender Trustee shall not make the election provided under Section 754 of the Code. The Eligible Lender Trustee shall be entitled to hire an independent accounting firm to perform the functions described in this Section 5.4 the reasonable fees and expenses of which shall be paid by the Depositor.