Common use of Federal Income Tax Allocations Clause in Contracts

Federal Income Tax Allocations. (a) Net income of the Trust for any calendar quarter as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated: (i) among the Certificate Owners as of the first day following the end of such quarter, in proportion to their ownership of the principal amount of Trust Certificates on such date, net income in an amount up to the sum of (A) the Certificate Interest Distributable Amount for such quarter, (B) interest on the excess, if any, of the Certificate Interest Distributable Amount for the preceding Distribution Date over the amount in respect of interest that is actually deposited in the Certificate Distribution Account on such preceding Distribution Date, to the extent permitted by law, at the Pass-Through Rate from such preceding Distribution Date through the current Distribution Date, (C) the portion of the market discount on the Contracts accrued during such quarter that is allocable to the excess, if any, of the initial aggregate principal amount of the Trust Certificates over their initial aggregate issue price and (D) any other amounts of income payable to the Certificateholders for such quarter; such sum to be reduced by any amortization by the Trust of premium on Contracts that corresponds to any excess of the issue price of Trust Certificates over their principal amount; and (ii) to the Depositor and the Company in the proportion of 99% and 1%, respectively, to the extent of any remaining net income. (b) If the net income of the Trust for any calendar quarter is insufficient for the allocations described in Section 2.10(a)(i), subsequent net income shall first be allocated to make up such shortfall before being allocated as provided in Section 2.11(a)(ii). Net losses of the Trust, if any, for any calendar quarter as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated to the Depositor and the Company in the proportion of 99% and 1%, respectively, to the extent the Depositor and the Company are reasonably expected to bear the economic burden of such net losses, and any remaining net losses shall be allocated among the Certificate Owners as of the first day following the end of such quarter in proportion to their ownership of the principal amount of Trust Certificates on such day. The Depositor and the Company are authorized to modify the allocations in this paragraph if necessary or appropriate, in its sole discretion, for the allocations to fairly reflect the income, gain, loss and deduction to the Depositor and the Company or to the Certificate Owners, or as otherwise required by the Code.

Federal Income Tax Allocations. (a) Net income of the Trust for any calendar quarter month, as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) ), shall be allocated: (i) among the Certificate Owners as of the first day following the end of such quartermonth, in proportion to their ownership of the principal amount of Trust Certificates on such date, net income in an amount up to the sum of (A) the Certificate Interest Distributable Amount for such quartermonth, (B) interest on the excess, if any, of the Certificate Interest Distributable Amount for the preceding Distribution Date over the amount in respect of interest that is actually deposited in the Certificate Distribution Account on such preceding Distribution Date, to the extent permitted by law, at the Pass-Through Certificate Rate from such preceding Distribution Date through the current Distribution Date, (C) the portion of the market discount on the Contracts accrued during such quarter month that is allocable to the excess, if any, of the initial aggregate principal amount of the Trust Certificates over their initial aggregate issue price and (D) any other amounts of income payable to the Certificateholders for such quartermonth; such sum to be reduced by any amortization by the Trust of premium on Contracts that corresponds to any excess of the issue price of Trust Certificates over their principal amount; and (ii) among the Residual Interestholders in proportion to the Depositor and Percentage Interest of the Company in the proportion Residual Interest of 99% and 1%, respectivelyeach Residual Interestholder, to the extent of any remaining net income. (b) If the net income of the Trust for any calendar quarter month is insufficient for the allocations described in Section 2.10(a)(i), subsequent net income shall first be allocated to make up such shortfall before being allocated as provided in Section 2.11(a)(ii2.10(a)(ii). Net losses of the Trust, if any, for any calendar quarter month as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated to the Depositor and the Company in the proportion of 99% and 1%, respectivelyResidual Interestholders, to the extent the Depositor and the Company Residual Interestholders are reasonably expected to bear the economic burden of such net losses, and any remaining net losses shall be allocated among the Certificate Owners as of the first day following the end of such quarter month in proportion to their ownership of the principal amount of Trust Certificates on such day. Any indebtedness allocated pursuant to Treasury Regulation Section 1.752-3(a)(3) shall be allocated to the Residual Interest. The Depositor and the Company are is authorized to modify the allocations in this paragraph if necessary or appropriate, in its sole discretion, for the allocations to fairly reflect the income, gain, loss and deduction to the Depositor and the Company or to the Certificate Owners, or as otherwise required by the Code.

Federal Income Tax Allocations. (a) Net income of the Trust for any calendar quarter month as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated: (ia) among the Certificate Owners as of the first day following the end of such quartermonth, in proportion to their ownership of the principal amount of Trust Certificates on such date, net income in an amount up to the sum of (Ai) the Certificate Certificateholders' Monthly Interest Distributable Amount for such quartermonth, (Bii) interest on the excess, if any, of the Certificate Certificateholders' Interest Distributable Amount for the preceding Distribution Date over the amount in respect of interest that is actually deposited in the Certificate Distribution Account on such preceding Distribution Date, to the extent permitted by law, at the Pass-Through Rate from such preceding Distribution Date through the current Distribution Date, (Ciii) the portion of the market discount on the Contracts Receivables accrued during such quarter month that is allocable to the excess, if any, of the initial aggregate principal amount of the Trust Certificates over their initial aggregate issue price price, (iv) any amount expected to be distributed to the Certificateholders pursuant to Section 5.07(g) of the Sale and Servicing Agreement (to the extent not previously allocated pursuant to this clause), and (Dv) any other amounts of income payable to the Certificateholders for such quartermonth; such sum to be reduced by any amortization by the Trust of premium on Contracts Receivables that corresponds to any excess of the issue price of Trust Certificates over their principal amount; and (iib) to the Depositor and the Company in the proportion of 99% and 1%, respectivelyCompany, to the extent of any remaining net income. (b) . If the net income of the Trust for any calendar quarter month is insufficient for the allocations described in Section 2.10(a)(i)clause (a) above, subsequent net income shall first be allocated to make up such shortfall before being allocated as provided in Section 2.11(a)(ii)the preceding sentence. Net losses of the Trust, if any, for any calendar quarter month as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated to the Depositor and the Company in the proportion of 99% and 1%, respectively, to the extent the Depositor and the Company are is reasonably expected to bear the economic burden of such net losses, and any remaining net losses shall be allocated among the Certificate Owners as of the first day Record Date following the end of such quarter month in proportion to their ownership of the principal amount of Trust Certificates on such dayRecord Date. The Depositor and the Company are is authorized to modify the allocations in this paragraph if necessary or appropriate, in its sole discretion, for the allocations to fairly reflect the economic income, gain, gain or loss and deduction to the Depositor and the Company or to the Certificate Owners, or as otherwise required by the Code.

Federal Income Tax Allocations. (a) Net income of the Trust for any calendar quarter as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated: (i) among the Certificate Owners as of the first day following the end of such quarter, in proportion to their ownership of the principal amount of Trust Certificates on such date, net income in an amount up to the sum of (A) the Certificate Interest Distributable Amount for such quarter, (B) interest on the excess, if any, of the Certificate Interest Distributable Amount for the preceding Distribution Date over the amount in respect of interest that is actually deposited in the Certificate Distribution Account on such preceding Distribution Date, to the extent permitted by law, at the Pass-Through Rate from such preceding Distribution Date through the current Distribution Date, (C) the portion of the market discount on the Contracts accrued during such quarter that is allocable to the excess, if any, of the initial aggregate principal amount of the Trust Certificates over their initial aggregate issue price and (D) any other amounts of income payable to the Certificateholders for such quarter; such sum to be reduced by any amortization by the Trust of premium on Contracts that corresponds to any excess of the issue price of Trust Certificates over their principal amount; and (ii) to the Depositor and the Company in the proportion of 99% and 1%, respectively, to the extent of any remaining net income. (b) If the net income of the Trust for any calendar quarter is insufficient for the allocations described in Section 2.10(a)(i2.11(a)(i), subsequent net income shall first be allocated to make up such shortfall before being allocated as provided in Section 2.11(a)(ii). Net losses of the Trust, if any, for any calendar quarter as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated to the Depositor and the Company in the proportion of 99% and 1%, respectively, to the extent the Depositor and the Company are reasonably expected to bear the economic burden of such net losses, and any remaining net losses shall be allocated among the Certificate Owners as of the first day following the end of such quarter in proportion to their ownership of the principal amount of Trust Certificates on such day. The Depositor and the Company are authorized to modify the allocations in this paragraph if necessary or appropriate, in its sole discretion, for the allocations to fairly reflect the income, gain, loss and deduction to the Depositor and the Company or to the Certificate Owners, or as otherwise required by the Code.and

Federal Income Tax Allocations. (a) Net income of the Trust for any calendar quarter month as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated: (ia) among the Certificate Owners as of the first day following the end of such quartermonth, in proportion to their ownership of the principal amount of Trust Certificates on such date, net income in an amount up to the sum of (Ai) the Certificate Certificateholders' Monthly Interest Distributable Amount for such quartermonth, (Bii) interest on the excess, if any, of the Certificate Certificateholders' Interest Distributable Amount for the preceding Distribution Date over the amount in respect of interest that is actually deposited in the Certificate Distribution Account on such preceding Distribution Date, to the extent permitted by law, at the Pass-Through Rate from such preceding Distribution Date through the current Distribution Date, (Ciii) the portion of the market discount on the Contracts Underlying Securities accrued during such quarter month that is allocable to the excess, if any, of the initial aggregate principal amount of the Trust Certificates over their initial aggregate issue price price, (iv) any amount expected to be distributed to the Certificateholders pursuant to Section [9.01(e)(i)] (to the extent not previously allocated pursuant to this clause), and (Dv) any other amounts of income payable to the Certificateholders for such quartermonth; such sum to be reduced by any amortization by the Trust of premium on Contracts Underlying Securities that corresponds to any excess of the issue price of Trust Certificates over their principal amount; and (iib) to the Depositor and the Company in the proportion of 99% and 1%, respectivelyCompany, to the extent of any remaining net income. (b) . If the net income of the Trust for any calendar quarter month is insufficient for the allocations described in Section 2.10(a)(i)clause (a) above, subsequent net income shall first be allocated to make up such shortfall before being allocated as provided in Section 2.11(a)(ii)the preceding sentence. Net losses of the Trust, if any, for any calendar quarter month as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated to the Depositor and the Company in the proportion of 99% and 1%, respectively, to the extent the Depositor and the Company are is reasonably expected to bear the economic burden of such net losses, and any remaining net losses shall be allocated among the Certificate Owners as of the first day Record Date following the end of such quarter month in proportion to their ownership of the principal amount of Trust Certificates on such dayRecord Date. The Depositor and the Company are is authorized to modify the allocations in this paragraph if necessary or appropriate, in its sole discretion, for the allocations to fairly reflect the economic income, gain, gain or loss and deduction to the Depositor and the Company or to the Certificate Owners, or as otherwise required by the Code.

Federal Income Tax Allocations. (a) Net income of the Trust ------------------------------ for any calendar quarter month, as determined for federal Federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) ), shall be allocated: (i) among the Certificate Owners Certificates as of the first day Record Date following the end of such quartermonth, in proportion to their ownership of the principal amount of Trust Certificates on such date, an amount of net income in an amount up to the sum of (Ai) the Certificate Interest Distributable Amount for such quarter, (B) interest on the excess, if any, of the Certificate Interest Distributable Amount for the preceding Distribution Date over the amount distributed in respect of interest that is actually deposited in the Certificate Distribution Account on such preceding Distribution Date, to the extent permitted by lawCertificateholders pursuant to Section 5.05(c) of the Sale and Servicing Agreement for such month, at the Pass-Through Rate from such preceding Distribution Date through the current Distribution Date, and (Cii) the portion of the market discount on the Contracts Home Loans accrued during such quarter month that is allocable to the excess, if any, of the initial aggregate principal amount of the Trust Certificates over their initial aggregate issue price and (D) any other amounts of income payable to the Certificateholders for such quarter; such sum to be reduced by any amortization by the Trust of premium on Contracts that corresponds to any excess of the issue price of Trust Certificates over their principal amountprice; and (ii) to the Depositor and the Company in the proportion of 99% and 1%Residual Interestholders, respectivelypro rata, to the extent of any remaining net income. (b) . If the net income of the Trust for any calendar quarter month is insufficient for the allocations described in Section 2.10(a)(i)clause (a) above, subsequent net income shall first be allocated to make up such shortfall before being allocated as provided in Section 2.11(a)(ii)the preceding sentence. Net losses of the Trust, if any, for any calendar quarter month, as determined for federal Federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) ), shall be allocated to the Depositor and the Company in the proportion of 99% and 1%, respectively, Residual Interestholders to the extent the Depositor and the Company Residual Interestholders are reasonably expected to bear the economic burden of such net losses, and any remaining net losses shall be allocated among the Certificate Owners Certificates as of the first day Record Date following the end of such quarter month in proportion to their ownership of the principal amount of Trust Certificates certificates on such dayRecord Date. The Depositor and the Company are authorized Any indebtedness allocated pursuant to modify the allocations in this paragraph if necessary or appropriate, in its sole discretion, for the allocations to fairly reflect the income, gain, loss and deduction Treasury Regulation Section 1.752 - 3(a)(3) shall be allocated to the Depositor and the Company or to the Certificate Owners, or as otherwise required by the CodeResidual Interest.

Federal Income Tax Allocations. (a) Net income of the Trust for any calendar quarter month as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated: (ia) among the Certificate Owners as of the first day Record Date following the end of such quartermonth, in proportion to their ownership of the principal amount of Trust Certificates on such date, net income in an amount up to the sum of (Ai) the Certificate Certificateholders' Monthly Interest Distributable Amount for such quartermonth, (Bii) interest on the excess, if any, of the Certificate Certificateholders' Interest Distributable Amount for the preceding Distribution Date over the amount in respect of interest that is actually deposited in the Certificate Distribution Account on such preceding Distribution Date, to the extent permitted by law, at the Pass-Through Rate from such preceding Distribution Date through the current Distribution Date, (Ciii) the portion of the market discount on the Contracts Mortgage Loans accrued during such quarter month that is allocable to the excess, if any, of the initial aggregate principal amount of the Trust Certificates over their initial aggregate issue price price, (iv) any amount expected to be distributed to the Certificateholders pursuant to the Master Servicing Agreement (to the extent not previously allocated pursuant to this clause), (v) any Certificateholders' Prepayment Premium distributable to the Certificateholders with respect to such month and (Dvi) any other amounts of income payable to the Certificateholders for such quartermonth; such sum to be reduced by any amortization by the Trust of premium on Contracts that corresponds to any excess of the issue price of Trust Certificates over their principal amount; and (ii) to the Depositor and the Company in the proportion of 99% and 1%, respectively, to the extent of any remaining net income. (b) If the net income of the Trust for any calendar quarter is insufficient for the allocations described in Section 2.10(a)(i), subsequent net income shall first be allocated to make up such shortfall before being allocated as provided in Section 2.11(a)(ii). Net losses of the Trust, if any, for any calendar quarter as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated to the Depositor and the Company in the proportion of 99% and 1%, respectively, to the extent the Depositor and the Company are reasonably expected to bear the economic burden of such net losses, and any remaining net losses shall be allocated among the Certificate Owners as of the first day following the end of such quarter in proportion to their ownership of the principal amount of Trust Certificates on such day. The Depositor and the Company are authorized to modify the allocations in this paragraph if necessary or appropriate, in its sole discretion, for the allocations to fairly reflect the income, gain, loss and deduction to the Depositor and the Company or to the Certificate Owners, or as otherwise required by the Code.amortization

Federal Income Tax Allocations. (a) Net income of the Trust ------------------------------ for any calendar quarter month as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated: (ia) among the Certificate Owners as of the first day following the end of such quartermonth, in proportion to their ownership of the principal amount of Trust Certificates on such date, net income in an amount up to the sum of (Ai) the Certificate Certificateholders' Monthly Interest Distributable Amount for such quartermonth, (Bii) interest on the excess, if any, of the Certificate Certificateholders' Interest Distributable Amount for the preceding Distribution Date over the amount in respect of interest that is actually deposited in the Certificate Distribution Account on such preceding Distribution Date, to the extent permitted by law, at the Pass-Through Rate from such preceding Distribution Date through the current Distribution Date, (Ciii) the portion of the market discount on the Contracts Receivables accrued during such quarter month that is allocable to the excess, if any, of the initial aggregate principal amount of the Trust Certificates over their initial aggregate issue price price, (iv) any amount expected to be distributed to the Certificateholders pursuant to Section 5.07(g) of the Sale and Servicing Agreement (to the extent not previously allocated pursuant to this clause), and (Dv) any other amounts of income payable to the Certificateholders for such quartermonth; such sum to be reduced by any amortization by the Trust of premium on Contracts Receivables that corresponds to any excess of the issue price of Trust Certificates over their principal amount; and (iib) to the Depositor and the Company in the proportion of 99% and 1%, respectivelyCompany, to the extent of any remaining net income. (b) . If the net income of the Trust for any calendar quarter month is insufficient for the allocations described in Section 2.10(a)(i)clause (a) above, subsequent net income shall first be allocated to make up such shortfall before being allocated as provided in Section 2.11(a)(ii)the preceding sentence. Net losses of the Trust, if any, for any calendar quarter month as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated to the Depositor and the Company in the proportion of 99% and 1%, respectively, to the extent the Depositor and the Company are is reasonably expected to bear the economic burden of such net losses, and any remaining net losses shall be allocated among the Certificate Owners as of the first day Record Date following the end of such quarter month in proportion to their ownership of the principal amount of Trust Certificates on such dayRecord Date. The Depositor and the Company are is authorized to modify the allocations in this paragraph if necessary or appropriate, in its sole discretion, for the allocations to fairly reflect the economic income, gain, gain or loss and deduction to the Depositor and the Company or to the Certificate Owners, or as otherwise required by the Code.

Federal Income Tax Allocations. (a) Net income of the Trust for any calendar quarter as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated: (i) among the Certificate Owners as of the first day following the end of such quarter, in proportion to their ownership of the principal amount of Trust Certificates on such date, net income in an amount up to the sum of (A) the Certificate Interest Distributable Amount for such quarter, (B) interest on the excess, if any, of the Certificate Interest Distributable Amount for the preceding Distribution Date over the amount in respect of interest that is actually deposited in the Certificate Distribution Account on such preceding Distribution Date, to the extent permitted by law, at the Pass-Through Rate from such preceding Distribution Date through the current Distribution Date, (C) the portion of the market discount on the Contracts accrued during such quarter that is allocable to the excess, if any, of the initial aggregate principal amount of the Trust Certificates over their initial aggregate issue price and (D) any other amounts of income payable to the Certificateholders for such quarter; such sum to be reduced by any amortization by the Trust of premium on Contracts that corresponds to any excess of the issue price of Trust Certificates over their principal amount; and (ii) to the Depositor and the Company in the proportion of 99% and 1%, respectively, to the extent of any remaining net income. (b) If the net income of the Trust for any calendar quarter is insufficient for the allocations described in Section 2.10(a)(i), subsequent net income shall first be allocated to make up such shortfall before being allocated as provided in Section 2.11(a)(ii). Net losses of the Trust, if any, for any calendar quarter as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated to the Depositor and the Company in the proportion of 99% and 1%, respectively, to the extent the Depositor and the Company are reasonably expected to bear the economic burden of such net losses, and any remaining net losses shall be allocated among the Certificate Owners as of the first day following the end of such quarter in proportion to their ownership of the principal amount of Trust Certificates on such day. The Depositor and the Company are authorized to modify the allocations in this paragraph if necessary or appropriate, in its sole discretion, for the allocations to fairly reflect the income, gain, loss and deduction to the Depositor and the Company or to the Certificate Owners, or as otherwise required by the Code.. ARTICLE THREE

Federal Income Tax Allocations. If Certificates are held by more than one person, (a) Net amounts paid to Certificateholders pursuant to Section 5.2(a)(i) shall be treated as "guaranteed payments" within the meaning of Section 707(c) of the Code; (b) to the extent that the characterization provided for in paragraph (a) of this Section is not respected, gross ordinary income of the Trust Issuer for any calendar quarter such month as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated: (i) allocated among the Certificate Owners Certificateholders as of the first day Record Date following the end of such quartermonth, in proportion to their ownership of the principal amount of Trust the Certificates on such date, net income in an amount up to the sum of (Ai) the Certificate Certificateholders' Monthly Interest Distributable Amount for such quartermonth, (Bii) interest on the excess, if any, of the Certificate Certificateholders' Interest Distributable Amount for the preceding Distribution Date over the amount in respect of interest at the Certificate Rate that is actually deposited in the Certificate Distribution Account on such preceding Distribution Date, to the extent permitted by law, at the Pass-Through Certificate Rate from such preceding Distribution Date through the current Distribution Date, and (Ciii) the portion of the market discount on the Contracts Receivables accrued during such quarter month that is allocable to the excess, if any, excess of the initial aggregate principal amount of the Trust Certificates over their initial aggregate issue price and (D) any other amounts of income payable to the Certificateholders for such quarter; such sum to be reduced by any amortization by the Trust of premium on Contracts that corresponds to any excess of the issue price of Trust Certificates over their principal amountprice; and (iic) thereafter all remaining net income of Issuer for such month as determined for federal income tax purposes (and each item of income, gain, credit, loss or deduction entering into the computation thereof) shall be allocated to the Depositor and the Company in the proportion of 99% and 1%, respectivelyDepositor, to the extent of any remaining net income. (b) thereof; If the net gross ordinary income of the Trust Issuer for any calendar quarter month is insufficient for the allocations described in Section 2.10(a)(iclause (b), subsequent net gross ordinary income shall first be allocated to make up such shortfall before being allocated as provided in Section 2.11(a)(iiclause (c). Net losses of the TrustIssuer, if any, for any calendar quarter month as determined for federal Federal income tax purposes (and each item of income, gain, loss loss, credit and deduction entering into the computation thereof) shall be allocated to the Depositor and the Company in the proportion of 99% and 1%, respectively, to the extent the Depositor and the Company are reasonably expected to bear the economic burden of such net losses, and any remaining net losses shall be allocated among the Certificate Owners as of the first day following the end of such quarter in proportion to their ownership of the principal amount of Trust Certificates on such day. The Depositor and the Company are authorized to modify the allocations in this paragraph if necessary or appropriate, in its sole discretion, for the allocations to fairly reflect the income, gain, loss and deduction to the Depositor and the Company or to the Certificate Owners, or as otherwise required by the Code.computation

Federal Income Tax Allocations. (a) Net income of the Trust for any calendar quarter month as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated: (ia) among the Certificate Owners as of the first day following the end of such quartermonth, in proportion to their ownership of the principal amount of Trust Certificates on such date, net income in an amount up to the sum of of: (Ai) the Certificate Certificateholders’ Monthly Interest Distributable Amount for such quartermonth, (Bii) interest on the excess, if any, of the Certificate Certificateholders’ Interest Distributable Amount for the preceding Distribution Date over the amount in respect of interest that is actually deposited in the Certificate Distribution Account on such preceding Distribution Date, to the extent permitted by law, at the Pass-Through Rate from such preceding Distribution Date through the current Distribution Date, (Ciii) the portion of the market discount on the Contracts Receivables accrued during such quarter month that is allocable to the excess, if any, of the initial aggregate principal amount of the Trust Certificates over their initial aggregate issue price price, (iv) any amount expected to be distributed to the Certificateholders pursuant to Section 5.07(g) of the Sale and Servicing Agreement (to the extent not previously allocated pursuant to this clause), and (Dv) any other amounts of income payable to the Certificateholders for such quartermonth; such sum to be reduced by any amortization by the Trust of premium on Contracts Receivables that corresponds to any excess of the issue price of Trust Certificates over their principal amount; and (iib) to the Depositor and the Company in the proportion of 99% and 1%, respectivelyCompany, to the extent of any remaining net income. (b) . If the net income of the Trust for any calendar quarter month is insufficient for the allocations described in Section 2.10(a)(i)clause (a) above, subsequent net income shall first be allocated to make up such shortfall before being allocated as provided in Section 2.11(a)(ii)the preceding sentence. Net losses of the Trust, if any, for any calendar quarter month as determined for federal income tax purposes (and each item of income, gain, loss and deduction entering into the computation thereof) shall be allocated to the Depositor and the Company in the proportion of 99% and 1%, respectively, to the extent the Depositor and the Company are is reasonably expected to bear the economic burden of such net losses, and any remaining net losses shall be allocated among the Certificate Owners as of the first day Record Date following the end of such quarter month in proportion to their ownership of the principal amount of Trust Certificates on such dayRecord Date. The Depositor and the Company are is authorized to modify the allocations in this paragraph if necessary or appropriate, in its sole discretion, for the allocations to fairly reflect the economic income, gain, gain or loss and deduction to the Depositor and the Company or to the Certificate Owners, or as otherwise required by the Code.