Common use of Grantor Trust Administration Clause in Contracts

Grantor Trust Administration. The assets of the Class EI Grantor Trust, consisting of the right to any Excess Interest in respect of the ARD Loan (in the case of the Class [EI] Certificates) and the related amounts in the Excess Interest Sub-account, shall be held by the Trustee for the benefit of the Holders of the Class [EI] Certificates, which Class [EI] Certificates will evidence 100% beneficial ownership of the related assets from and after the Closing Date. The assets of the Class A-3-1FL Grantor Trust, consisting of the Class A-3-1FL Regular Interest, the Swap Contract and the related amounts in the Floating Rate Account, shall be held by the Trustee for the benefit of the Holders of the Class [A-3-1FL] Certificates, which Class [A-3-1FL] Certificates will evidence 100% beneficial ownership of the related assets from and after the Closing Date. It is intended that the portions of the Trust consisting of the Class A-3-1FL Grantor Trust and the Class EI Grantor Trust will be treated as grantor trusts for federal income tax purposes, within the meaning of subpart E, part I of subchapter J of the Code, and each of the parties to this Agreement agrees that it will not take any action that is inconsistent with establishing or maintaining such treatment. Under no circumstances may the Trustee vary the assets of the Class A-3-1FL Grantor Trust or Class EI Grantor Trust so as to take advantage of variations in the market so as to improve the rate of return of Holders of the Class A-3-1FL or Class [EI] Certificates. The Trustee and the Paying Agent shall be deemed to hold and shall account for the Class A-3-1FL Grantor Trust and the Class EI Grantor Trust separate and apart from the assets of the REMIC I, REMIC II and REMIC III created hereunder. In furtherance of such intention, the Paying Agent shall furnish or cause to be furnished to the Class A-3-1FL and Class [EI] Certificateholders and shall file, or cause to be filed with the Internal Revenue Service, together with Form 1041 or such other form as may be applicable, information returns with respect to income relating to their shares of the income and expenses of the Class A-3-1FL Grantor Trust and the Class EI Grantor Trust, at the time or times and in the manner required by the Code.

Grantor Trust Administration. The assets of the Class EI Grantor Trust, consisting of the right to any Excess Interest in respect of the ARD Loan (in the case of the Class [EI] Certificates) Loans and the related amounts in the Excess Interest Sub-account, shall be held by the Trustee for the benefit of the Holders of the Class [EI] EI Certificates, which Class [EI] Certificates will evidence 100% beneficial ownership of the related assets from and after the Closing Date. The assets of the Class A-3-1FL Grantor Trust, consisting of the Class A-3-1FL Regular Interest, the Swap Contract and the related amounts in the Floating Rate Account, shall be held by the Trustee for the benefit of the Holders of the Class [A-3-1FL] Certificates, which Class [A-3-1FL] EI Certificates will evidence 100% beneficial ownership of the related assets from and after the Closing Date. It is intended that the portions of the Trust consisting of the Class A-3-1FL Grantor Trust and the Class EI Grantor Trust will be treated as a grantor trusts trust for federal income tax purposes, within the meaning of subpart E, part I of subchapter J of the Code, and each of the parties to this Agreement agrees that it will not take any action that is inconsistent with establishing or maintaining such treatment. In addition, the Class A-MFL and Class A-JFL Certificates are hereby designated as undivided beneficial interests in the related Class of Floating Rate Regular Interest, the related Swap Transaction and the proceeds thereof in the related Floating Rate Account, and it is intended that each such portion of the Trust Fund will be treated as a separate grantor trust for Federal income tax purposes within the meaning of subpart E, part I of Subchapter J of the Code, and each of the parties to this Agreement agrees that it will not take any action that is inconsistent with establishing or maintaining such treatment. Under no circumstances may the Trustee or the Paying Agent vary the assets of the Class A-3-1FL EI Grantor Trust or Class EI either Floating Rate Grantor Trust so as to take advantage of variations in the market so as to improve the rate of return of Holders of the Class A-3-1FL EI Certificates or the related Class [EI] of Floating Rate Certificates, as the case may be. The Trustee and the Paying Agent shall be deemed to hold and shall account for the Class A-3-1FL Grantor Trust and each of the Class EI Grantor Trust and the Floating Rate Grantor Trusts separate and apart from the assets of the REMIC I, REMIC II and REMIC III created hereunder. In furtherance of such intention, the Paying Agent shall furnish or cause to be furnished to the Class A-3-1FL EI and Class [EI] Floating Rate Certificateholders and shall file, or cause to be filed with the Internal Revenue Service, together with Form 1041 (or, if the WHFIT Regulations are applicable, Form 1099) or such other form as may be applicable, information returns with respect to income relating to their shares of the income and expenses of the Class A-3-1FL EI Grantor Trust and or the Class EI related Floating Rate Grantor Trust, as applicable, at the time or times and in the manner required by the Code.

Grantor Trust Administration. (a) The parties intend that the segregated pool of assets of the Class EI Grantor Trust, consisting of the right to any Excess Interest in respect of the ARD Loan of: (in the case of the Class [EI] Certificatesi) and the related amounts in the Excess Interest Sub-account, shall be held by and the Trustee for the benefit of the Holders of Excess Interest Distribution Account; (ii) the Class [EI] Certificates, which Class [EI] Certificates will evidence 100% beneficial ownership of the related assets from and after the Closing Date. The assets of the Class A-3-1FL Grantor Trust, consisting of the Class A-3-1FL A-2FL Regular Interest, the Class A-2FL Swap Contract and Contract, the related amounts in the Class A-2FL Floating Rate Account, shall be held by the Trustee for the benefit of the Holders of Account and proceeds thereof and (iii) the Class [A-3A-1FL] CertificatesJFL Regular Interest, which Class [A-3-1FL] Certificates will evidence 100% beneficial ownership of the related assets from and after the Closing Date. It is intended that the portions of the Trust consisting of the Class A-3A-1FL Grantor Trust and JFL Swap Contract, the Class EI Grantor Trust will A-JFL Floating Rate Account and proceeds thereof shall be treated as a "grantor trusts for federal income tax purposes, within the meaning of subpart E, part I of subchapter J of trust" under the Code, and each of the parties to this Agreement agrees that it will not take any action that is inconsistent with establishing or maintaining such treatment. Under no circumstances may the Trustee vary the assets of the Class A-3-1FL Grantor Trust or Class EI Grantor Trust so as to take advantage of variations in the market so as to improve the rate of return of Holders of the Class A-3-1FL or Class [EI] Certificates. The Trustee and the Paying Agent provisions thereof shall be deemed to hold and shall account for the Class A-3-1FL Grantor Trust and the Class EI Grantor Trust separate and apart from the assets of the REMIC I, REMIC II and REMIC III created hereunderinterpreted consistently with this intention. In furtherance of such intentionintention with respect to the Grantor Trusts, the Paying Agent Trustee shall furnish or cause to be furnished to the Class A-3-1FL and Class [EI] Certificateholders and shall file, file or cause to be filed annually with the Internal Revenue Service, IRS together with IRS Form 1041 or such other form as may be applicable, information returns applicable and shall furnish or cause to be furnished annually: (i) with respect to income relating the Excess Interest Grantor Trust, to their shares of the income and expenses Holders of the Class A-3-1FL V Certificates, their allocable share of income with respect to Excess Interest as such amounts accrue or are received, as the case may be, after the related Anticipated Repayment Date; (ii) with respect to the Class A-2FL Grantor Trust Trust, to the Class A-2FL Certificateholders, their allocable shares of income and expense with respect to the Class A-2FL Regular Interest and the Class EI A-2FL Swap Contract; and (iii) with respect to the Class A-JFL Grantor Trust, to the Class A-JFL Certificateholders, their allocable shares of income and expense with respect to the Class A-JFL Regular Interest and the Class A-2FL Swap Contract, each at the time or times and in the manner required by the Code. In addition, the Trustee shall use its best efforts to obtain a taxpayer identification number as soon as possible after the Closing Date (but no later than the first payment date under the Class A-2FL Swap Contract and the Class A-JFL Swap Contract) for the Class A-2FL Grantor Trust and the Class A-JFL Grantor Trust and shall deliver or cause to be delivered the federal taxpayer identification number of each of the Class A-2FL Grantor Trust and the Class A-JFL Grantor Trust on an IRS Form W-9 to the Class A-2FL Swap Counterparty or the Class A-2FL Swap Counterparty (as applicable) and, if requested by the Class A-2FL Swap Counterparty or the Class A-2FL Swap Counterparty (as applicable) (unless not permitted under federal income tax law), an applicable IRS Form W-8IMY. Under no circumstances shall the Trustee, the Master Servicer or the Special Servicer have the power to vary the investment of the Class A-2FL Certificateholders, the Class A-JFL Certificateholders or the Class V Certificateholders in the related Grantor Trust to take advantage of variations in the market rate of interest to improve their rate of return.

Grantor Trust Administration. The assets of the Class EI EI/Class EI-L3 Grantor Trust, consisting of the right to any Excess Interest in respect of the ARD Loan (in the case of the Class [EI Certificates) and Additional L-3 Interest (in the case of the Class EI] -L3 Certificates) and the related amounts in the Excess Interest Sub-account, shall be held by the Trustee for the benefit of the Holders of the Class [EI and Class EI] -L3 Certificates, which Class [EI and Class EI] -L3 Certificates will evidence 100% beneficial ownership of the related assets from and after the Closing Date. The assets of the Class A-3-1FL Grantor Trust, consisting of the Class A-3-1FL Regular Interest, the Swap Contract and the related amounts in the Floating Rate Account, shall be held by the Trustee for the benefit of the Holders of the Class [A-3-1FL] 1FL Certificates, which Class [A-3-1FL] 1FL Certificates will evidence 100% beneficial ownership of the related assets from and after the Closing Date. It is intended that the portions of the Trust consisting of the Class A-3-1FL Grantor Trust and the Class EI EI/Class EI-L3 Grantor Trust will be treated as grantor trusts for federal income tax purposes, within the meaning of subpart E, part I of subchapter J of the Code, and each of the parties to this Agreement agrees that it will not take any action that is inconsistent with establishing or maintaining such treatment. Under no circumstances may the Trustee vary the assets of the Class A-3-1FL Grantor Trust or Class EI EI/Class EI-L3 Grantor Trust so as to take advantage of variations in the market so as to improve the rate of return of Holders of the Class A-3-1FL 1FL, Class EI or Class [EI] -L3 Certificates. The Trustee and the Paying Agent shall be deemed to hold and shall account for the Class A-3-1FL Grantor Trust and the Class EI EI/Class EI-L3 Grantor Trust separate and apart from the assets of the REMIC I, REMIC II and REMIC III created hereunder. In furtherance of such intention, the Paying Agent shall furnish or cause to be furnished to the Class A-3-1FL 1FL, Class EI and Class [EI] -L3 Certificateholders and shall file, or cause to be filed with the Internal Revenue Service, together with Form 1041 or such other form as may be applicable, information returns with respect to income relating to their shares of the income and expenses of the Class A-3-1FL Grantor Trust and the Class EI EI/Class EI-L3 Grantor Trust, at the time or times and in the manner required by the Code.

Grantor Trust Administration. The assets parties intend that the portion of the Class EI Grantor Trust, Trust Fund consisting of the right to any Excess Interest in respect of the ARD Loan (in the case of the Class [EI] Certificatesi) and the related amounts in the Excess Interest Sub-account, shall be held by and the Trustee for the benefit of the Holders of Excess Interest Distribution Account and (ii) the Class [EI] Certificates, which Class [EI] Certificates will evidence 100% beneficial ownership of the related assets from and after the Closing Date. The assets of the Class A-3A-1FL Grantor Trust, consisting of the Class A-3-1FL MFL Regular Interest, the Class A-MFL Swap Contract and Contract, the related amounts in the Class A-MFL Floating Rate Account, Account and proceeds thereof shall be held by the Trustee for the benefit of the Holders of the Class [A-3-1FL] Certificates, which Class [A-3-1FL] Certificates will evidence 100% beneficial ownership of the related assets from and after the Closing Date. It is intended that the portions of the Trust consisting of the Class A-3-1FL Grantor Trust and the Class EI Grantor Trust will each be treated as a "grantor trusts for federal income tax purposes, within the meaning of subpart E, part I of subchapter J of trust" under the Code, and each of the parties to this Agreement agrees that it will not take any action that is inconsistent with establishing or maintaining such treatment. Under no circumstances may the Trustee vary the assets of the Class A-3-1FL Grantor Trust or Class EI Grantor Trust so as to take advantage of variations in the market so as to improve the rate of return of Holders of the Class A-3-1FL or Class [EI] Certificates. The Trustee and the Paying Agent provisions thereof shall be deemed to hold and shall account for the Class A-3-1FL Grantor Trust and the Class EI Grantor Trust separate and apart from the assets of the REMIC I, REMIC II and REMIC III created hereunderinterpreted consistently with this intention. In furtherance of such intentionintention with respect to the Grantor Trust, the Paying Agent Trustee shall furnish or cause to be furnished to the Class A-3-1FL and Class [EI] Certificateholders and shall file, file or cause to be filed annually with the Internal Revenue Service, IRS together with IRS Form 1041 or such other form as may be applicable, information returns applicable and shall furnish or cause to be furnished annually (i) with respect to income relating the Excess Interest Grantor Trust, to their shares of the income and expenses Holders of the Class A-3V Certificates, their allocable share of income with respect to Excess Interest as such amounts accrue or are received, as the case may be, after the related Anticipated Repayment Date and (ii) with respect to the Class A-1FL MFL Grantor Trust Trust, to the Class A-MFL Certificateholders, their allocable shares of income and expense with respect to the Class A-MFL Regular Interest and the Class EI Grantor TrustA-MFL Swap Contract, each at the time or times and in the manner required by the Code. In addition, the Trustee shall use its best efforts to obtain a taxpayer identification number as soon as possible after the Closing Date (but no later than the first payment date under the Class A-MFL Swap Contract) for the Class A-MFL Grantor Trust and shall deliver or cause to be delivered the federal taxpayer identification number of the Class A-MFL Grantor Trust on an IRS Form W-9 to the Class A-MFL Swap Counterparty and, if requested by the Class A-MFL Swap Counterparty (unless not permitted under federal income tax law), an applicable IRS Form W-8IMY. Under no circumstances shall the Trustee, the Master Servicer or the Special Servicer have the power to vary the investment of the Class A-MFL Certificateholders or the Class V Certificateholders in the related Grantor Trust to take advantage of variations in the market rate of interest to improve their rate of return.

Grantor Trust Administration. (a) The parties intend that the segregated pool of assets consisting of : (i) the Class A-FL Regular Interest, the Class A-FL Swap Contract, the Class A-FL Floating Rate Account and proceeds thereof and (ii) the Excess Interest and the Excess Interest Distribution Account shall be treated as a “grantor trust” under the Code, and the provisions thereof shall be interpreted consistently with this intention. In furtherance of such intention, the Trustee shall file or cause to be filed annually with the IRS together with IRS Form 1041 (or, in the event the Grantor Trust is a WHFIT, information will be provided on Form 1099) or such other form as may be applicable and shall furnish or cause to be furnished annually: (i) with respect to the Class A-FL Grantor Trust, to the Holders of the Class EI Grantor TrustA-FL Certificates, consisting their allocable shares of income and expense with respect to the right Class A-FL Regular Interest and the Class A-FL Swap Contract; and (ii) to any Excess Interest in respect of the ARD Loan (in the case Holders of the Class [EI_] Certificates) and , their allocable share of income with respect to Excess Interest as such amounts accrue or are received, as the case may be, after the related amounts in Anticipated Repayment Date. In addition, the Excess Interest SubTrustee shall use its best efforts to obtain a taxpayer identification number as soon as possible after the Closing Date (but no later than the first payment date under the Class A-accountFL Swap Contract) for the Class A-FL Grantor Trust and shall deliver or cause to be delivered the federal taxpayer identification number of each of the Class A-FL Grantor Trust on an IRS Form W-9 to the Class A-FL Swap Counterparty and, shall be held if requested by the Trustee for Class A-FL Swap Counterparty (unless not permitted under federal income tax law), an applicable IRS Form W-8IMY. Under no circumstances shall the benefit Trustee, the Trustee, the Master Servicer or the Special Servicer have the power to vary the investment of the Holders of the Class [EI] Certificates, which Class [EI] A-FL Certificates will evidence 100% beneficial ownership of the related assets from and after the Closing Date. The assets of the Class A-3-1FL Grantor Trust, consisting of the Class A-3-1FL Regular Interest, the Swap Contract and the related amounts in the Floating Rate Account, shall be held by the Trustee for the benefit of the Holders of the Class [A-3-1FL] Certificates, which Class [A-3-1FL] Certificates will evidence 100% beneficial ownership of the related assets from and after the Closing Date. It is intended that the portions of the Trust consisting of the Class A-3-1FL Grantor Trust and the Class EI Grantor Trust will be treated as grantor trusts for federal income tax purposes, within the meaning of subpart E, part I of subchapter J of the Code, and each of the parties to this Agreement agrees that it will not take any action that is inconsistent with establishing or maintaining such treatment. Under no circumstances may the Trustee vary the assets of the Class A-3-1FL Grantor Trust or Class EI Grantor Trust so as to take advantage of variations in the market so as rate of interest to improve the their rate of return return. Notwithstanding the foregoing, unless otherwise notified by the beneficial owner of Holders of the Class A-3-1FL or a Class [EI_] Certificates. The Certificate that such Certificate is registered in the name of a nominee or other middleman on behalf of such beneficial owner, the Trustee and shall not treat the Paying Agent shall be deemed to hold and shall account for the Class A-3-1FL Grantor Trust and the Class EI Grantor Trust separate and apart from the assets of the REMIC I, REMIC II and REMIC III created hereunder. In furtherance of such intention, the Paying Agent shall furnish or cause to be furnished to the Class A-3-1FL and Class [EI] Certificateholders and shall file, or cause to be filed with the Internal Revenue Service, together with Form 1041 or such other form as may be applicable, information returns with respect to income relating to their shares of the income and expenses of the Class A-3-1FL Grantor Trust and the Class EI Grantor Trust, at the time or times and in the manner required by the Codea WHFIT.

Grantor Trust Administration. (a) The parties intend that the segregated pool of assets consisting of : (i) the Class A-FL Regular Interest, the Class A-FL Swap Contract, the Class A-FL Floating Rate Account and proceeds thereof, (ii) the Excess Interest and the Excess Interest Distribution and (iii) the Class EC Regular Interests Account shall be treated as a “grantor trust” under the Code, and the provisions thereof shall be interpreted consistently with this intention. In furtherance of such intention, the Trustee shall file or cause to be filed annually with the IRS together with IRS Form 1041 (or, in the event the Grantor Trust is a WHFIT, information will be provided on Form 1099) or such other form as may be applicable and shall furnish or cause to be furnished annually: (i) with respect to the Class A-FL Grantor Trust, to the Holders of the Class EI Grantor TrustA-FL Certificates, consisting their allocable shares of income and expense with respect to the Class A-FL Regular Interest and the Class A-FL Swap Contract, (ii) to the Holders of the right Class [_] Certificates, their allocable share of income with respect to any Excess Interest as such amounts accrue or are received, and (iii) in respect of the ARD Loan (in Class EC Regular Interests, the case holders of the Class [EIB], Class [C] Certificates) and Class PST Certificates as the case may be, after the related amounts in Anticipated Repayment Date. In addition, the Excess Interest SubTrustee shall use its best efforts to obtain a taxpayer identification number as soon as possible after the Closing Date (but no later than the first payment date under the Class A-accountFL Swap Contract) for the Class A-FL Grantor Trust and shall deliver or cause to be delivered the federal taxpayer identification number of each of the Class A-FL Grantor Trust on an IRS Form W-9 to the Class A-FL Swap Counterparty and, shall be held if requested by the Trustee for Class A-FL Swap Counterparty (unless not permitted under federal income tax law), an applicable IRS Form W-8IMY. Under no circumstances shall the benefit Trustee, the Trustee, the Master Servicer or the Special Servicer have the power to vary the investment of the Holders of the Class [EI] Certificates, which Class [EI] A-FL Certificates will evidence 100% beneficial ownership of the related assets from and after the Closing Date. The assets of the Class A-3-1FL Grantor Trust, consisting of the Class A-3-1FL Regular Interest, the Swap Contract and the related amounts in the Floating Rate Account, shall be held by the Trustee for the benefit of the Holders of the Class [A-3-1FL] Certificates, which Class [A-3-1FL] Certificates will evidence 100% beneficial ownership of the related assets from and after the Closing Date. It is intended that the portions of the Trust consisting of the Class A-3-1FL Grantor Trust and the Class EI Grantor Trust will be treated as grantor trusts for federal income tax purposes, within the meaning of subpart E, part I of subchapter J of the Code, and each of the parties to this Agreement agrees that it will not take any action that is inconsistent with establishing or maintaining such treatment. Under no circumstances may the Trustee vary the assets of the Class A-3-1FL Grantor Trust or Class EI Grantor Trust so as to take advantage of variations in the market so as rate of interest to improve the their rate of return return. Notwithstanding the foregoing, unless otherwise notified by the beneficial owner of Holders of the Class A-3-1FL or a Class [EI_] Certificates. The Certificate that such Certificate is registered in the name of a nominee or other middleman on behalf of such beneficial owner, the Trustee and shall not treat the Paying Agent shall be deemed to hold and shall account for the Class A-3-1FL Grantor Trust and the Class EI Grantor Trust separate and apart from the assets of the REMIC I, REMIC II and REMIC III created hereunder. In furtherance of such intention, the Paying Agent shall furnish or cause to be furnished to the Class A-3-1FL and Class [EI] Certificateholders and shall file, or cause to be filed with the Internal Revenue Service, together with Form 1041 or such other form as may be applicable, information returns with respect to income relating to their shares of the income and expenses of the Class A-3-1FL Grantor Trust and the Class EI Grantor Trust, at the time or times and in the manner required by the Codea WHFIT.

Grantor Trust Administration. (a) The parties intend that the segregated pool of assets of consisting of: (i) the Class EI Grantor Trust, consisting of the right to any Excess Interest in respect of the ARD Loan (in the case of the Class [EI] Certificates) and the related amounts in the Excess Interest Sub-account, shall be held by the Trustee for the benefit of the Holders of the Class [EI] Certificates, which Class [EI] Certificates will evidence 100% beneficial ownership of the related assets from and after the Closing Date. The assets of the Class A-3-1FL Grantor Trust, consisting of the Class A-3-1FL A-2FL Regular Interest, the Class A-2FL Swap Contract and Contract, the related amounts in the Class A-2FL Floating Rate Account, shall be held by the Trustee for the benefit of the Holders of Account and proceeds thereof and (ii) the Class [A-3A-1FL] CertificatesMFL Regular Interest, which Class [A-3-1FL] Certificates will evidence 100% beneficial ownership of the related assets from and after the Closing Date. It is intended that the portions of the Trust consisting of the Class A-3A-1FL Grantor Trust and MFL Swap Contract, the Class EI Grantor Trust will A-MFL Floating Rate Account and proceeds thereof shall be treated as a "grantor trusts for federal income tax purposes, within the meaning of subpart E, part I of subchapter J of trust" under the Code, and each of the parties to this Agreement agrees that it will not take any action that is inconsistent with establishing or maintaining such treatment. Under no circumstances may the Trustee vary the assets of the Class A-3-1FL Grantor Trust or Class EI Grantor Trust so as to take advantage of variations in the market so as to improve the rate of return of Holders of the Class A-3-1FL or Class [EI] Certificates. The Trustee and the Paying Agent provisions thereof shall be deemed to hold and shall account for the Class A-3-1FL Grantor Trust and the Class EI Grantor Trust separate and apart from the assets of the REMIC I, REMIC II and REMIC III created hereunderinterpreted consistently with this intention. In furtherance of such intentionintention with respect to the Grantor Trusts, the Paying Agent Trustee shall furnish or cause to be furnished to the Class A-3-1FL and Class [EI] Certificateholders and shall file, file or cause to be filed annually with the Internal Revenue Service, IRS together with IRS Form 1041 or such other form as may be applicable, information returns applicable and shall furnish or cause to be furnished annually: (i) with respect to income relating the Class A-2FL Grantor Trust, to their shares of the income and expenses Holders of the Class A-3-1FL Grantor Trust A-2FL Certificates, their allocable shares of income and expense with respect to the Class A-2FL Regular Interest and the Class EI A-2FL Swap Contract; and (ii) with respect to the Class A-MFL Grantor Trust, to the Holders of the Class A-MFL Certificates, their allocable shares of income and expense with respect to the Class A-MFL Regular Interest and the Class A-2FL Swap Contract, each at the time or times and in the manner required by the Code. In addition, the Trustee shall use its best efforts to obtain a taxpayer identification number as soon as possible after the Closing Date (but no later than the first payment date under the Class A-2FL Swap Contract and the Class A-MFL Swap Contract) for the Class A-2FL Grantor Trust and the Class A-MFL Grantor Trust and shall deliver or cause to be delivered the federal taxpayer identification number of each of the Class A-2FL Grantor Trust and the Class A-MFL Grantor Trust on an IRS Form W-9 to the Class A-2FL Swap Counterparty or the Class A-2FL Swap Counterparty (as applicable) and, if requested by the Class A-2FL Swap Counterparty or the Class A-2FL Swap Counterparty (as applicable) (unless not permitted under federal income tax law), an applicable IRS Form W-8IMY. Under no circumstances shall the Trustee, the Master Servicer or the Special Servicer have the power to vary the investment of the Holders of the Class A-2FL or Class A-MFL Certificates in the related Grantor Trust to take advantage of variations in the market rate of interest to improve their rate of return.