Common use of Federal Information Returns and Reports to Certificateholders Clause in Contracts

Federal Information Returns and Reports to Certificateholders. (a) The books of the Trust Fund shall reflect all payments made with respect to the Mortgage Loans, and amounts attributable to the Class A Certificateholders, the Class B Certificateholders, the Class C Certificateholders, the Class R-LT Certificateholder and the Class R-UT Certificateholder. The Trust Fund intends to allocate all excess inclusion income to the Upper-Tier REMIC, and specifically to the Class R-UT Certificateholder. At all times, the Trustee shall take all actions consistent with this intention. In addition, with respect to the Lower-Tier REMIC, the Trustee shall account for distributions made from the Lower-Tier REMIC as made on the first day of each calendar month. Further, the Trustee shall account for income of the Lower-Tier REMIC under the all-OID method at the Alternate Certificate Rate and shall use the aggregation method as provided in Treasury Regulation ss. 1.1275-2(c). (b) The Trustee shall prepare and file or cause to be filed with the Internal Revenue Service at the times and in the manner required by the Code or applicable Treasury Regulations all Federal tax or information returns with respect to the Upper-Tier REMIC and the Lower-Tier REMIC and the Certificates, which tax or information returns contain such information as may be required by the Code or applicable Treasury Regulations. The Class R-LT Certificateholder may, upon reasonable notice to the Trustee, review such tax or information returns prior to filing with the Internal Revenue Service. The Trustee also shall furnish to Holders of Certificates such statements or information at the times and in the manner as the Code or applicable Treasury Regulations may require such holders to be furnished, regardless of by whom. For this purpose, the Trustee may, but need not, rely on any proposed regulations of the United States Department of the Treasury. The Trustee shall indicate the election to treat the Trust Fund (exclusive of the Mortgage 100(SM) Pledge Agreements, the Parent Power(R) Agreements and the Carryover Reserve Fund (including the funds therein)) as two REMICs in such manner as the Code or applicable Treasury regulations may prescribe. The Trustee shall sign all required tax or information returns; provided, however, that the Trustee shall have no obligation to prepare, file or otherwise deal with partnership tax information or returns. In the event that partnership tax information or returns is required by the Internal Revenue Service, the Mortgage Loan Seller will prepare and file all necessary returns. The initial Class R-LT Certificateholder is hereby designated as the initial "tax matters person" (within the meaning of Temp. Treas. Reg. ss. 1.860F-4T(d)). In the event that the Code or applicable Treasury Regulations prohibit the Trustee from signing tax or information returns or other statements, or the Class R-LT Certificateholder from acting as tax matters person (as an agent or otherwise), the Trustee shall take whatever action that in its sole good faith judgment is necessary for the proper filing of such information returns or for the provision of a tax matters person, including designation of the Class R-LT Certificateholder to sign such returns. The Class R-LT Certificateholder and the Class R-UT Certificateholder shall each be bound by this Section 5.15. [End of Article V]

Federal Information Returns and Reports to Certificateholders. (a) The books For Federal income tax purposes, the taxable year of the Trust Fund REMIC shall reflect all payments made with respect to the Mortgage Loans, be a calendar year and amounts attributable to the Class A Certificateholders, the Class B Certificateholders, the Class C Certificateholders, the Class R-LT Certificateholder and the Class R-UT Certificateholder. The Trust Fund intends to allocate all excess inclusion income to the Upper-Tier REMIC, and specifically to the Class R-UT Certificateholder. At all times, the Trustee shall take all actions consistent with this intention. In addition, with respect to maintain or cause the Lower-Tier REMIC, maintenance of the Trustee shall account for distributions made from the Lower-Tier books of each REMIC as made on the first day accrual method of each calendar month. Further, the Trustee shall account for income of the Lower-Tier REMIC under the all-OID method at the Alternate Certificate Rate and shall use the aggregation method as provided in Treasury Regulation ss. 1.1275-2(c)accounting. (b) The Trustee shall prepare and file or cause to be filed with the Internal Revenue Service Federal tax information returns or elections required to be made by the Trustee hereunder with respect to any REMIC and the Certificates containing such information and at the times and in the manner required by the Code or applicable Treasury Regulations all Federal tax or information returns with respect to the Upper-Tier REMIC and the Lower-Tier REMIC and the Certificates, which tax or information returns contain such information as may be required by the Code or applicable Treasury Regulations. The Class R-LT Certificateholder mayregulations, upon reasonable notice to the Trustee, review such tax or information returns prior to filing with the Internal Revenue Service. The Trustee also and shall furnish to Holders each Holder of Certificates at any time during the calendar year for which such returns or reports are made such statements or information at the times and in the manner as may be required thereby. In connection with the Code or applicable Treasury Regulations may require such holders to be furnished, regardless of by whom. For this purposeforegoing, the Trustee may, but need not, rely on any proposed regulations shall provide the name and address of the United States Department person who can be contacted to obtain information required to be reported to the holders of regular interests in the TreasuryREMIC (the "REMIC Reporting Agent") as required by IRS Form 8811. The Trustee shall indicate make the election elections to treat the Trust Fund as a REMIC (exclusive of which election shall apply to the Mortgage 100(SMtaxable period ending December 31, 1999 and each calendar year thereafter) Pledge Agreements, the Parent Power(R) Agreements and the Carryover Reserve Fund (including the funds therein)) as two REMICs in such manner as the Code or applicable Treasury regulations may prescribe. The Trustee shall sign all tax information returns filed pursuant to this Section and any other returns as may be required tax or information returns; providedby the Code, howeverand in doing so shall rely entirely upon, that the Trustee and shall have no obligation to prepareliability for information provided by, file or otherwise deal with partnership tax information or returns. In the event that partnership tax information or returns is required by the Internal Revenue Servicecalculations provided by, the Mortgage Loan Seller will prepare and file all necessary returnsor the Servicer. The initial Class R-LT Certificateholder Holder of the Residual Certificate is hereby designated as the initial "tax matters personTax Matters Person" (within the meaning of Temp. Treas. Reg. ssxx.xx.. 1. 1.860F-4T(d860F-4(d))) for the REMIC. The Trustee is hereby designated and appointed as the agent of each such Tax Matters Person. Any Holder of a Residual Certificate will by acceptance thereof appoint the Trustee as agent and attorney-in-fact for the purpose of acting as Tax Matters Person for the REMIC during such time as the Trustee does not own any such Residual Certificate. In the event that the Code or applicable Treasury Regulations regulations prohibit the Trustee from signing tax or information returns or other statements, or the Class R-LT Certificateholder Trustee from acting as tax matters person Tax Matters Person (as an agent or otherwise), the Trustee shall take whatever action that in its sole good faith judgment is necessary for the proper filing of such information returns or for the provision of a tax matters person, including designation of the Class R-LT Certificateholder Holder of a Residual Certificate to sign such returnsreturns or act as tax matters person. The Class R-LT Certificateholder and the Class R-UT Certificateholder Each Holder of a Residual Certificate shall each be bound by this Section. (c) The Trustee shall provide upon request such information (which shall be provided upon reasonable compensation to the Trustee) as required in Section 5.15. [End 860D(a)(6)(B) of Article V]the Code to the Internal Revenue Service, to any Person purporting to transfer a Residual Certificate to a Person other than a transferee permitted by Section 5.05(b), and to any regulated investment company, real estate investment trust, common trust fund, partnership, trust, estate, organization described in Section 1381 of the Code, or nominee holding an interest in a pass-through entity described in Section 860E(e)(6) of the Code, any record holder of which is not a transferee permitted by Section 5.02(e) (or which is deemed by statute to be an entity with a disqualified member). (d) The Trustee shall prepare and file or cause to be filed any state income tax returns required under Applicable State Law with respect to the REMIC or the Trust Fund.

Federal Information Returns and Reports to Certificateholders. (a) The For Federal income tax purposes, the taxable year of the REMIC Trust shall be a calendar year and the Trustee shall maintain or cause the maintenance of the books of the REMIC Trust Fund shall reflect all payments made with respect to the Mortgage Loans, and amounts attributable to the Class A Certificateholders, the Class B Certificateholders, the Class C Certificateholders, the Class R-LT Certificateholder and the Class R-UT Certificateholder. The Trust Fund intends to allocate all excess inclusion income to the Upper-Tier REMIC, and specifically to the Class R-UT Certificateholder. At all times, the Trustee shall take all actions consistent with this intention. In addition, with respect to the Lower-Tier REMIC, the Trustee shall account for distributions made from the Lower-Tier REMIC as made assets on the first day accrual method of each calendar month. Further, the Trustee shall account for income of the Lower-Tier REMIC under the all-OID method at the Alternate Certificate Rate and shall use the aggregation method as provided in Treasury Regulation ss. 1.1275-2(c)accounting. (b) The Trustee shall prepare and file or cause to be filed with the Internal Revenue Service Federal tax information returns with respect to the REMIC Trust, the Trust Fund, if applicable, and the Certificates containing such information and at the times and in the manner required by the Code or applicable Treasury Regulations all Federal tax or information returns with respect to the Upper-Tier REMIC and the Lower-Tier REMIC and the Certificates, which tax or information returns contain such information as may be required by the Code or applicable Treasury Regulations. The Class R-LT Certificateholder mayregulations, upon reasonable notice to the Trustee, review such tax or information returns prior to filing with the Internal Revenue Service. The Trustee also and shall furnish to Holders each Holder of Certificates at any time during the calendar year for which such returns or reports are made such statements or information at the times and in the manner as may be required thereby. In connection with the Code or applicable Treasury Regulations may require such holders to be furnished, regardless of by whom. For this purposeforegoing, the Trustee may, but need not, rely on any proposed regulations shall provide the name and address of the United States Department person who can be contacted to obtain information required to be reported to the holders of regular interests in the TreasuryREMIC Trust (the "REMIC Reporting Agent") as required by IRS Form 8811. The Trustee shall indicate make the election elections to treat the REMIC Trust Fund as a REMIC (exclusive of which election shall apply to the Mortgage 100(SMtaxable period ending December 31, 1997 and each calendar year thereafter) Pledge Agreements, the Parent Power(R) Agreements and the Carryover Reserve Fund (including the funds therein)) as two REMICs in such manner as the Code or applicable Treasury regulations may prescribe. The Trustee shall sign all tax information returns filed pursuant to this Section and any other returns as may be required tax or information returns; providedby the Code, howeverand in doing so shall rely entirely upon, that the Trustee and shall have no obligation to prepare, file or otherwise deal with partnership tax liability for information or returns. In calculations contained in the event that partnership tax information or returns is required by the Internal Revenue Service, the Mortgage Loan Seller will prepare and file all necessary returnsPooled Certificate Distribution Date Statements. The initial Class R-LT Certificateholder Trustee is hereby designated as the initial "tax matters personTax Matters Person" (within the meaning of Temp. Treas. Reg. ss' 1.860F-4(d)) for the REMIC Trust. 1.860F-4T(d))Any Holder of a Residual Certificate will by acceptance thereof appoint the Trustee as agent and attorney-in-fact for the purpose of acting as Tax Matters Person for the REMIC Trust during such time as the Trustee does not own any such Residual Certificate. In the event that the Code or applicable Treasury Regulations regulations prohibit the Trustee from signing tax or information returns or other statements, or the Class R-LT Certificateholder Trustee from acting as tax matters person Tax Matters Person (as an agent or otherwise), the Trustee shall take whatever action that in its sole good faith judgment is necessary for the proper filing of such information returns or for the provision of a tax matters person, including designation of the Class R-LT Certificateholder Holder of the Residual Certificate to sign such returnsreturns or act as tax matters person. The Class R-LT Certificateholder and Each Holder of the Class R-UT Certificateholder Residual Certificate shall each be bound by this Section. (c) The Trustee shall provide upon request such information as is required in Section 5.15. [End 860D(a)(6)(B) of Article V]the Code to the Internal Revenue Service, to any Person purporting to transfer a Residual Certificate to a Person other than a transferee permitted by Section 5.05(b), and to any regulated investment company, real estate investment trust, common trust fund, partnership, trust, estate, organization described in Section 1381 of the Code, or nominee holding an interest in a pass-through entity described in Section 860E(e)(6) of the Code, any record holder of which is not a transferee permitted by Section 5.05(b) (or which is deemed by statute to be an entity with a disqualified member). (d) The Trustee shall prepare and file or cause to be filed any state income tax returns required with respect to the REMIC Trust or the Trust Fund.

Federal Information Returns and Reports to Certificateholders. (a) The books of the Trust Fund shall reflect all payments made with respect to the Mortgage Loans, and amounts attributable to the Class A CertificateholdersFor Federal income tax purposes, the Class B Certificateholders, taxable year for the Class C Certificateholders, the Class R-LT Certificateholder REMIC shall be a calendar year and the Class R-UT Certificateholder. The Trust Fund intends to allocate all excess inclusion income to the Upper-Tier REMIC, and specifically to the Class R-UT Certificateholder. At all times, the Trustee shall take all actions consistent with this intention. In addition, with respect to maintain or cause the Lower-Tier REMIC, maintenance of the Trustee shall account for distributions made from books of each of the Lower-Tier REMIC as made on the first day accrual method of each calendar month. Further, the Trustee shall account for income of the Lower-Tier REMIC under the all-OID method at the Alternate Certificate Rate and shall use the aggregation method as provided in Treasury Regulation ss. 1.1275-2(c)accounting. (b) The Trustee shall prepare and file or cause to be filed with the Internal Revenue Service federal tax information returns with respect to the REMIC, the Trust, if applicable, and the Certificates containing such information and at the times and in the manner required by the Code or applicable Treasury Regulations all Federal tax or information returns with respect to the Upper-Tier REMIC and the Lower-Tier REMIC and the Certificates, which tax or information returns contain such information as may be required by the Code or applicable Treasury Regulations. The Class R-LT Certificateholder mayregulations, upon reasonable notice to the Trustee, review such tax or information returns prior to filing with the Internal Revenue Service. The Trustee also and shall furnish to Holders each Holder of Certificates at any time during the calendar year for which such returns or reports are made such statements or information at the times and in the manner as may be required thereby. In connection with the Code or applicable Treasury Regulations may require such holders to be furnished, regardless of by whom. For this purposeforegoing, the Trustee may, but need not, rely on any proposed regulations shall provide the name and address of the United States Department person who can be contacted to obtain information required to be reported to the holders of regular interests in the Treasuryof REMIC (the "REMIC Reporting Agent") as required by IRS Form 8811. The Trustee shall indicate make the election elections to treat the Trust Fund of REMIC as a REMIC (exclusive of which election shall apply to the Mortgage 100(SMtaxable period ending December 31, 2001 and each calendar year thereafter) Pledge Agreements, the Parent Power(R) Agreements and the Carryover Reserve Fund (including the funds therein)) as two REMICs in such manner as the Code or applicable Treasury regulations may prescribe. The Trustee shall sign all tax information returns filed pursuant to this Section and any other returns as may be required tax or information returns; providedby the Code, howeverand in doing so shall rely entirely upon, that the Trustee and shall have no obligation to prepare, file or otherwise deal with partnership tax liability for information or returns. In calculations contained in the event that partnership tax information or returns is required by the Internal Revenue Service, the Mortgage Loan Seller will prepare and file all necessary returnsPooled Security Distribution Date Statements. The initial Holder of the Class R-LT Certificateholder R Certificate is hereby designated as the initial "tax matters personTax Matters Person" (within the meaning of Temp. Treas. Reg. ssss.1.860F-4(d)) for the REMIC. 1.860F-4T(d))The Trustee is hereby designated and appointed as the agent of such Tax Matters Person. Any Holder of a Class R Certificate will by acceptance thereof appoint the Trustee as agent and attorney-in-fact for the purpose of acting as Tax Matters Person during such time as the Trustee does not own the Class R Certificate. In the event that the Code or applicable Treasury Regulations regulations prohibit the Trustee from signing tax or information returns or other statements, or the Class R-LT Certificateholder Trustee from acting as tax matters person Tax Matters Person (as an agent or otherwise), the Trustee shall take whatever action that in its sole good faith judgment is necessary for the proper filing of such information returns or for the provision of a tax matters person, including designation of the Holder of the Class R-LT Certificateholder R Certificate to sign such returnsreturns or act as tax matters person. The Class R-LT Certificateholder and Each Holder of the Class R-UT Certificateholder R Certificate shall each be bound by this Section. (c) The Trustee shall provide upon request such information as is required in Section 5.15. [End 860D(a)(6)(B) of Article V]the Code to the Internal Revenue Service, to any Person purporting to transfer a Class R Certificate to a Person other than a transferee permitted by Section 4.05(b), and to any regulated investment company, real estate investment trust, common trust fund, partnership, trust, estate, organization described in Section 1381 of the Code, or nominee holding an interest in a pass-through entity described in Section 860E(e)(6) of the Code, any record holder of which is not a transferee permitted by Section 4.05(b) (or which is deemed by statute to be an entity with a disqualified member). (d) The Trustee shall prepare and file or cause to be filed any New York State income tax returns required with respect to the REMIC or the Trust and upon receipt of the notice and confirmation required by the terms of Section 3.06(f) to prepare and file or cause to be filed any tax returns required by any other states with respect to the REMIC or the Trust.

Federal Information Returns and Reports to Certificateholders. (a) The books of the Trust Fund shall reflect all payments made with respect to the Mortgage Loans, and amounts attributable to the Class A CertificateholdersFor Federal income tax purposes, the Class B Certificateholders, the Class C Certificateholders, the Class R-LT Certificateholder taxable year of each REMIC shall be a calendar year and the Class R-UT Certificateholder. The Trust Fund intends to allocate all excess inclusion income to the Upper-Tier REMIC, and specifically to the Class R-UT Certificateholder. At all times, the Trustee shall take all actions consistent with this intention. In addition, with respect to maintain or cause the Lower-Tier REMIC, maintenance of the Trustee shall account for distributions made from the Lower-Tier books of each REMIC as made on the first day accrual method of each calendar month. Further, the Trustee shall account for income of the Lower-Tier REMIC under the all-OID method at the Alternate Certificate Rate and shall use the aggregation method as provided in Treasury Regulation ss. 1.1275-2(c)accounting. (b) The Trustee shall prepare and file or cause to be filed with the Internal Revenue Service Federal tax information returns or elections required to be made by the Trustee hereunder with respect to any REMIC and the Certificates containing such information and at the times and in the manner required by the Code or applicable Treasury Regulations all Federal tax or information returns with respect to the Upper-Tier REMIC and the Lower-Tier REMIC and the Certificates, which tax or information returns contain such information as may be required by the Code or applicable Treasury Regulations. The Class R-LT Certificateholder mayregulations, upon reasonable notice to the Trustee, review such tax or information returns prior to filing with the Internal Revenue Service. The Trustee also and shall furnish to Holders each Holder of Certificates at any time during the calendar year for which such returns or reports are made such statements or information at the times and in the manner as may be required thereby. In connection with the Code or applicable Treasury Regulations may require such holders to be furnished, regardless of by whom. For this purposeforegoing, the Trustee may, but need not, rely on any proposed regulations shall provide the name and address of the United States Department person who can be contacted to obtain information required to be reported to the holders of regular interests in each REMIC (the Treasury"REMIC Reporting Agent") as required by IRS Form 8811. The Trustee shall indicate make the election elections to treat each REMIC as a REMIC (which election shall apply to the Trust Fund (exclusive of the Mortgage 100(SMtaxable period ending December 31, 1999 and each calendar year thereafter) Pledge Agreements, the Parent Power(R) Agreements and the Carryover Reserve Fund (including the funds therein)) as two REMICs in such manner as the Code or applicable Treasury regulations may prescribe. The Trustee shall sign all tax information returns filed pursuant to this Section and any other returns as may be required tax or information returns; providedby the Code, howeverand in doing so shall rely entirely upon, that the Trustee and shall have no obligation to prepareliability for information provided by, file or otherwise deal with partnership tax information or returns. In the event that partnership tax information or returns is required by the Internal Revenue Servicecalculations provided by, the Mortgage Loan Seller will prepare and file all necessary returnsor the Servicer. The initial Class R-LT Certificateholder Holder of the Residual Certificate is hereby designated as the initial "tax matters personTax Matters Person" (within the meaning of Temp. Treas. Reg. ssxx.xx.. 1. 1.860F-4T(d860F-4(d))) for each REMIC. The Trustee is hereby designated and appointed as the agent of each such Tax Matters Person. Any Holder of a Residual Certificate will by acceptance thereof appoint the Trustee as agent and attorney-in-fact for the purpose of acting as Tax Matters Person for each REMIC during such time as the Trustee does not own any such Residual Certificate. In the event that the Code or applicable Treasury Regulations regulations prohibit the Trustee from signing tax or information returns or other statements, or the Class R-LT Certificateholder Trustee from acting as tax matters person Tax Matters Person (as an agent or otherwise), the Trustee shall take whatever action that in its sole good faith judgment is necessary for the proper filing of such information returns or for the provision of a tax matters person, including designation of the Class R-LT Certificateholder Holder of a Residual Certificate to sign such returnsreturns or act as tax matters person. The Class R-LT Certificateholder and the Class R-UT Certificateholder Each Holder of a Residual Certificate shall each be bound by this Section. (c) The Trustee shall provide upon request such information (which shall be provided upon reasonable compensation to the Trustee) as required in Section 5.15. [End 860D(a)(6)(B) of Article V]the Code to the Internal Revenue Service, to any Person purporting to transfer a Residual Certificate to a Person other than a transferee permitted by Section 5.05(b), and to any regulated investment company, real estate investment trust, common trust fund, partnership, trust, estate, organization described in Section 1381 of the Code, or nominee holding an interest in a pass-through entity described in Section 860E(e)(6) of the Code, any record holder of which is not a transferee permitted by Section 5.02(e) (or which is deemed by statute to be an entity with a disqualified member). (d) The Trustee shall prepare and file or cause to be filed any state income tax returns required under Applicable State Law with respect to each REMIC or the Trust Fund.