Common use of Creation of the Grantor Trust Clause in Contracts

Creation of the Grantor Trust. The Class NR Certificates are hereby designated as undivided beneficial interests in the portion of the Trust Fund consisting of Excess Interest and the Excess Interest Distribution Account and proceeds thereof and the Class EC Certificates are hereby designated as undivided beneficial interests in the portion of the Trust Fund consisting of the uncertificated regular interests in the Upper-Tier REMIC represented by any Exchangeable Certificates that have been exchanged and converted for the Class EC Certificates and the Class EC Distribution Account, which portions shall be treated as a grantor trust within the meaning of subpart E, part I of subchapter J of the Code. For federal income tax purposes, the regular interests in the Upper-Tier REMIC represented by the classes of Exchangeable Certificates (or portions thereof) that have been exchanged for Class EC Certificates shall be deemed to continue to be outstanding and represented by the Class EC Certificates, and upon a reconversion of Class EC Certificates for Exchangeable Certificates, shall again be deemed to be represented by such Exchangeable Certificates. [End of Article II]

Creation of the Grantor Trust. The Class NR Z Certificates are hereby designated as undivided beneficial interests in the portion of the Trust Fund consisting of Excess Interest and the Excess Interest Distribution Account and proceeds thereof and the Class EC Certificates are hereby designated as undivided beneficial interests in the portion of the Trust Fund consisting of the uncertificated regular interests in the Upper-Tier REMIC represented by any Exchangeable Certificates that have been exchanged and converted for the Class EC Certificates and the Class EC Distribution Account, which portions shall be treated as a grantor trust within the meaning of subpart E, part I of subchapter J of the Code. For federal income tax purposes, the regular interests in the Upper-Tier REMIC represented by the classes of Exchangeable Certificates (or portions thereof) that have been exchanged for Class EC Certificates shall be deemed to continue to be outstanding and represented by the Class EC Certificates, and upon a reconversion of Class EC Certificates for Exchangeable Certificates, shall again be deemed to be represented by such Exchangeable Certificates. [End of Article II]

Creation of the Grantor Trust. The (i) Class NR Certificates are hereby designated as undivided beneficial interests in the portion of the Trust Fund consisting of Excess Interest and the Excess Interest Distribution Account and proceeds thereof and the (ii) Class EC Certificates are hereby designated as undivided beneficial interests in the portion of the Trust Fund consisting of the uncertificated regular interests in the Upper-Tier REMIC represented by any Exchangeable Certificates that have been exchanged and converted for the Class EC Certificates and the Class EC Distribution Account, which portions shall be treated as a grantor trust within the meaning of subpart E, part I of subchapter J of the Code. For federal income tax purposes, the regular interests in the Upper-Tier REMIC represented by the classes of Exchangeable Certificates (or portions thereof) that have been exchanged for Class EC Certificates shall be deemed to continue to be outstanding and represented by the Class EC Certificates, and upon a reconversion of Class EC Certificates for Exchangeable Certificates, shall again be deemed to be represented by such Exchangeable Certificates. [End of Article II]