Common use of REMIC Administration Clause in Contracts

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I, the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest and the interests represented by the Certificates.

REMIC Administration. (a) The An election will be made by the Certificate Administrator on behalf of the Trustee shall elect to treat each Trust REMIC the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Collection Account, the Reserve Accounts and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and, to the extent of the Trust’s interest therein, any related REO Properties as a REMIC under the Code and(such REMIC being herein designated as “REMIC I”), if necessary, under applicable state lawother than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Loan. Each such election Such elections will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC I I, and the REMIC I Residual Interest (which shall be evidenced by the Class R-I Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC I. The An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC II”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC II II, and the REMIC II Residual Interest (which shall be evidenced by the Class R-II Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC II. The An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC III”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Interests are issued. For purposes of such election, the Class A A-0, Xxxxx X-0, Class A-SB, Class A-0, Xxxxx X-0, Class D, Class E, Class F and Class G Certificates, the Mezzanine Certificates, the Swap-IO InterestEX XXXXX III Regular Interests, the Class CE H REMIC III Regular Interest and the Class P Interest X REMIC III Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC III III, and the REMIC III Residual Interest (which shall be evidenced by the Class R-III Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee Certificate Administrator shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest Interests and the interests represented by the CertificatesREMIC III Interests.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I, the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The REMIC II Regular Interests Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest M-3 Certificates shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Class M-4 Certificates shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Class M-5 Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO The Class CE Certificates shall be designated as the Regular Interest Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any “"interests” " in any Trust REMIC (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest Interests and the interests represented by the Certificates.

REMIC Administration. (a) The An election will be made by the Certificate Administrator on behalf of the Trustee shall elect to treat each Trust REMIC the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Collection Account, the Reserve Accounts and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and, to the extent of the Trust’s interest therein, any related REO Properties as a REMIC under the Code and(such REMIC being herein designated as “REMIC I”), if necessary, under applicable state lawother than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Loan. Each such election Such elections will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC I I, and the REMIC I Residual Interest (which shall be evidenced by the Class R-I Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC I. The An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC II”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC II II, and the REMIC II Residual Interest (which shall be evidenced by the Class R-II Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC II. The An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC III”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Interests are issued. For purposes of such election, the Class A X-0, Xxxxx X-0, Class A-AB, Class X-0, Xxxxx X-0, Class D, Class E, Class F and Class G Certificates, the Mezzanine Certificates, the Swap-IO InterestEC Trust REMIC III Regular Interests, the Class CE H REMIC III Regular Interest and the Class P Interest X REMIC III Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC III III, and the REMIC III Residual Interest (which shall be evidenced by the Class R-III Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee Certificate Administrator shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest Interests and the interests represented by the CertificatesREMIC III Interests.

REMIC Administration. (a) The An election will be made by the Certificate Administrator on behalf of the Trustee shall elect to treat each Trust REMIC the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Collection Account, the Reserve Accounts and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and, to the extent of the Trust’s interest therein, any related REO Properties as a REMIC under the Code and(such REMIC being herein designated as “REMIC I”), if necessary, under applicable state lawother than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Loan. Each such election Such elections will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC I I, and the REMIC I Residual Interest (which shall be evidenced by the Class R-I Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC I. The An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC II”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC II II, and the REMIC II Residual Interest (which shall be evidenced by the Class R-II Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC II. The An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC III”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Interests are issued. For purposes of such election, the Class A A-0, Xxxxx X-0, Class A-SB, Class A-3, Class A-0, Xxxxx X-0, Class D, Class E, Class F, Class G and Class H Certificates, the Mezzanine CertificatesEX XXXXX III Regular Interests, the Swap-IO InterestSwap REMIC III Regular Interests, the Class CE J REMIC III Regular Interest and the Class P Interest X REMIC III Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC III III, and the REMIC III Residual Interest (which shall be evidenced by the Class R-III Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee Certificate Administrator shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest Interests and the interests represented by the CertificatesREMIC III Interests.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Account, the Interest Reserve Account, the Distribution Account and the Reserve Account, the Insurance Policies and any related amounts REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to the Serviced Companion Loan. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate class of "regular interests" in REMIC I and the Class R-I Interest Certificates shall be designated as the Residual Interest sole class of "residual interests" in REMIC I. The An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole class of the "residual interests" in REMIC II. The Class A Certificates, An election will be made by the Mezzanine Certificates, Paying Agent to treat the Swap-IO Interestsegregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class CE Interest A-1, Class A-2, Class A-3, Class A-4, Class A-5, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O, Class X-1 and the Class P Interest X-2 Certificates, shall be designated as the Regular Interests "regular interests" in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole class of "residual interests" in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VIIII. The Trustee and the Paying Agent shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest REMIC III Regular Certificates and the interests represented by the Residual Certificates.

REMIC Administration. (a) The An election will be made by the Certificate Administrator on behalf of the Trustee shall elect to treat each Trust REMIC the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Collection Account, the Reserve Accounts and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and, to the extent of the Trust’s interest therein, any related REO Properties as a REMIC under the Code and(such REMIC being herein designated as “REMIC I”), if necessary, under applicable state lawother than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Loan. Each such election Such elections will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC I I, and the REMIC I Residual Interest (which shall be evidenced by the Class R-I Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC I. The An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC II”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC II II, and the REMIC II Residual Interest (which shall be evidenced by the Class R-II Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC II. The An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC III”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Interests are issued. For purposes of such election, the Class A X-0, Xxxxx X-0, Class A-SB, Class A-3, Class X-0, Xxxxx X-0, Class D, Class E, Class F, Class G and Class H Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest XX XXXXX III Regular Interests and the Class P Interest X REMIC III Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC III III, and the REMIC III Residual Interest (which shall be evidenced by the Class R-III Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee Certificate Administrator shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest Interests and the interests represented by the CertificatesREMIC III Interests.

REMIC Administration. (a) The An election will be made by the Certificate Administrator on behalf of the Trustee shall elect to treat each Trust REMIC the segregated pool of assets consisting of the Mortgage Loans (other than any Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Collection Account, the Reserve Accounts and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and, to the extent of the Trust’s interest therein, any related REO Properties as a REMIC under the Code and(such REMIC being herein designated as “REMIC I”), if necessary, under applicable state lawother than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Loan. Each such election Such elections will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC I I, and the REMIC I Residual Interest (which shall be evidenced by the Class R-I Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC I. The An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC II”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC II II, and the REMIC II Residual Interest (which shall be evidenced by the Class R-II Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC II. The An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC III”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Interests are issued. For purposes of such election, the Class A A-0, Xxxxx X-0, Class A-AB, Class A-0, Xxxxx X-0, Class D, Class E, Class F, Class G and Class H Certificates, the Mezzanine Certificates, the Swap-IO InterestEX XXXXX III Regular Interests, the Class CE J REMIC III Regular Interest and the Class P Interest X REMIC III Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC III III, and the REMIC III Residual Interest (which shall be evidenced by the Class R-III Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee Certificate Administrator shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest Interests and the interests represented by the CertificatesREMIC III Interests.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I, the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The For the purposes of the REMIC election in respect of REMIC II, the REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A CertificatesCertificates and the Mezzanine Certificates (other than the right to receive amounts from the Net WAC Rate Carryover Reserve Account or the Swap Account or the obligation to make payments to the Swap Account), the Mezzanine Certificates, the Swap-IO Class CE-1 Interest, the Class CE CE-2 Interest, the Class P Interest and the Class P Swap-IO Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Class CE-1 Certificates shall be designated as the Regular Interests Interest in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class P Certificates shall be designated as the Regular Interests Interest in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAPSwap-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class CE-2 Certificates shall be designated as the Regular Interest in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest Interests and the interests represented by the Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will shall be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I, (i) the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The I, (ii) the REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, (iii) the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest REMIC III Regular Interests shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The , (iv) the Class A Certificates, the Mezzanine Certificates (exclusive of the right to receive payments from the Net WAC Carryover Reserve Account or the Swap Account or the obligation to make payments to the Swap Account), the Class SWAP-IO Interest, the Class CE Certificates Interest and the Class P Interest shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P , (v) the Class CE Certificates (exclusive of any obligation to make payments to the Net WAC Rate Carryover Reserve Account or the Swap Account) shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO V, (vi) the Class P Certificates shall be designated as the Regular Interest Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VIVI and (vii) REMIC VII Regular Interest SWAP-IO shall be designated as the Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests, the Class CE Interest, the Class P Interest, the SwapClass SWAP-IO Interest and the interests represented by the Certificates.

REMIC Administration. (a) The Trustee shall elect Pursuant to treat each Trust the 000 Xxxxxx Xxxxxx Pari Passu REMIC as a REMIC under the Code andDeclaration, if necessary, under applicable state law. Each such an election will be made by the Trustee to treat the segregated pool of assets consisting of the 000 Xxxxxx Xxxxxx Pari Passu Loan and all proceeds thereof or any real or personal property acquired with respect thereto as a REMIC (the "111 Eighth Avenue Pari Passu Loan REMIC") under the Code, other than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Mortgage Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on December 31, 2005. For purposes of such election, the 000 Xxxxxx Xxxxxx Pari Passu Loan REMIC Regular Interests shall each be designated as the Class of "regular interests" in the 000 Xxxxxx Xxxxxx Pari Passu Loan REMIC and the Class R-EA Certificates shall be designated as the sole Class of "residual interests" in the 000 Xxxxxx Xxxxxx Pari Passu Loan REMIC. An election will be made by the Trustee to treat the segregated pool of assets consisting of the Majority Mortgage Loans, the 000 Xxxxxx Xxxxxx Pari Passu Loan REMIC Regular Interest, such amounts related to the Majority Mortgage Loans as shall from time to time be held in the Certificate Account and the Interest Reserve Account, such amounts related to the Majority Mortgage Loans and the 000 Xxxxxx Xxxxxx Pari Passu Loan REMIC Regular Interest as shall from time to time be held in the Distribution Account, the related Insurance Policies and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Mortgage Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For purposes of such election, the REMIC I Regular Interests shall each be designated as a separate Class of "regular interests" in REMIC I and the REMIC I Residual Interest shall be designated as the sole Class of "residual interests" in REMIC I. An election will be made by the Trustee to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole Class of the "residual interests" in REMIC II. The Class A Certificates, An election will be made by the Mezzanine Certificates, Trustee to treat the Swap-IO Interestsegregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class CE Interest and the A-1, Class X-0, Xxxxx X-0, Class A-AB, Class A-4, Class A-J, Class X-1, Class X-2, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O, Class P Interest and Class Q Certificates shall be designated as the Regular Interests "regular interests" in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole Class of "residual interests" in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VIIII. The Trustee shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the 000 Xxxxxx Xxxxxx Pari Passu Loan REMIC Regular Interest, REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest REMIC III Regular Interests and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee REMIC elections as set forth in the Preliminary Statement shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. The regular interests and residual interest in each REMIC shall be as designated in the Preliminary Statement. For the purposes of the REMIC election elections in respect of the Trust Fund, (i) the REMIC I1 Regular Interests will represent the “regular interests” in REMIC 1, the Class R-1 Interest will constitute the sole class of “residual interests” in REMIC I 1, (ii) the REMIC 2 Regular Interests shall be designated as will represent the Regular Interests “regular interests” in REMIC I and 2, the Class R-I R-2 Interest shall be designated as will constitute the Residual Interest sole class of “residual interests” in REMIC I. The REMIC II Regular Interests shall be designated as 2, (iii) the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, Class M Certificates and the Swap-IO InterestClass C Certificates (exclusive of any right to receive distributions from the Net WAC Rate Carryover Reserve Account in respect of the Net WAC Rate Carryover Amount or the Swap Account or any obligation to make payments to the Swap Account), the Class CE IO Interest and the Class P Interest shall be designated as the Regular Interests “regular interests” in REMIC III 3 and the Class R-3 Interest will constitute the sole class of “residual interests” in REMIC 3, (iv) the Class C Certificates will represent ownership of “regular interests” in REMIC 4 and the Class R-4 Interest will constitute the sole class of “residual interests” in REMIC 4, (v) the Class P Certificates will represent ownership of “regular interests” in REMIC 5 and the Class R-5 Interest will constitute the sole class of “residual interests” in REMIC 5, (vi) the REMIC 6 Regular Interest SWAP IO will represent ownership of “regular interests” in REMIC 6 and the Class R-6 Interest will constitute the sole class of “residual interests” in REMIC 6, (vii) the Class R Certificates will evidence ownership of the Class R-1 Interest, Class R-2 Interest and Class R-3 Interest and (viii) the Class R-III X Certificates will evidence ownership of the Class R-4 Interest, the Class R-5 Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IVR-6 Interest. The P Certificates shall be designated as the Regular Interests in REMIC V Securities Administrator and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) in any REMIC created hereunder other than (a) the REMIC I 1 Regular Interests, the REMIC II 2 Regular Interests, the REMIC 3 Regular Interests, the REMIC 4 Regular Interests, the REMIC 5 Regular Interests or the REMIC 6 Regular Interests, the ownership of which is represented by the Class CE A and Class M Certificates, the SWAP IO, the Class C Certificates and the Class P Certificates and (b) the Class R-1 Interest, the Class P R-2 Interest, the Swap-IO Class R-3 Interest, the Class R-4 Interest, the Class R-5 Interest and the interests represented by Class R-6 Interest. The Securities Administrator will apply for an Employee Identification Number from the Certificates.IRS via form SS-4 or any other acceptable method for each Trust REMIC

REMIC Administration. (a) The An election will be made by the Certificate Administrator on behalf of the Trustee shall elect to treat each Trust REMIC the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Collection Account, the Reserve Accounts and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and, to the extent of the Trust’s interest therein, any related REO Properties as a REMIC under the Code and(such REMIC being herein designated as “REMIC I”), if necessary, under applicable state lawother than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Loan. Each such election Such elections will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC I I, and the REMIC I Residual Interest (which shall be evidenced by the Class R-I Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC I. The An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC II”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC II II, and the REMIC II Residual Interest (which shall be evidenced by the Class R-II Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC II. The An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code (such 369 REMIC being herein designated as “REMIC III”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Interests are issued. For purposes of such election, the Class A X-0, Xxxxx X-0, Class A-SB, Class A-3, Class X-0, Xxxxx X-0, Class D, Class E, Class F, Class G and Class H Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest XX XXXXX III Regular Interests and the Class P Interest X REMIC III Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC III III, and the REMIC III Residual Interest (which shall be evidenced by the Class R-III Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee Certificate Administrator shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest Interests and the interests represented by the CertificatesREMIC III Interests.

REMIC Administration. (a) The Trustee Certificate Administrator shall elect make elections or cause elections to be made to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state lawApplicable State and Local Tax Law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Uncertificated Lower-Tier Interests and the Certificates are issued. For the purposes of the REMIC election in respect of REMIC Ithe Upper-Tier REMIC, each Class of the REMIC I Regular Interests Certificates shall be designated as the Regular Interests “regular interests” (or in REMIC I the case of an exchange and conversion of Class A-S, Class B and Class C Certificates for Class EC Certificates, such “regular interests” shall be deemed to be held by the Trustee in uncertificated form unless reconverted to Class A-S, Class B and Class C Certificates) and the Class R-I UR Interest shall be designated as the Residual Interest sole class of “residual interests” in the Upper-Tier REMIC. For purposes of the REMIC I. The REMIC II Regular election in respect of the Lower-Tier REMIC, each Class of Uncertificated Lower-Tier Interests and the Subordinate Loan-Specific Certificates shall be designated as the Regular Interests in REMIC II a class of “regular interests” and the Class R-II LR Interest shall be designated as the Residual Interest sole class of “residual interests” in the Lower-Tier REMIC. For purposes of the REMIC II. The Class A Certificates, election in respect of the Mezzanine Certificates, the SwapU-IO InterestHaul Self Storage Pool 5 Trust Pari Passu Companion Loan REMIC, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE UH5 Certificates shall be designated as the Regular Interests in REMIC IV “regular interests” and an uncertificated interest represented by the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P R Certificates shall be designated as the Regular Interests sole class of “residual interests” in REMIC V and the Class RU-V Interest shall be designated as Haul Self Storage Pool 5 Trust Pari Passu Companion Loan REMIC. None of the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as Special Servicer, the Regular Interest in REMIC VI and Master Servicer nor the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) in any Trust REMIC other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest and the interests represented by the Certificatesforegoing interests.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I, the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest interest shall be designated as the Residual Interest in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest REMIC III Regular Interests shall be designated as the Regular Interests in REMIC III and the Class R-III Interest interest shall be designated as the Residual Interest in REMIC III. The CE Certificates REMIC IV Regular Interests shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest interest shall be designated as the Residual Interest in REMIC IV. The P Certificates REMIC V Regular Interests shall be designated as the Regular Interests in REMIC V and the Class R-V Interest interest shall be designated as the Residual Interest in REMIC V. The REMIC VI Regular Interest SWAP-IO Interests shall be designated as the Regular Interest Interests in REMIC VI and the Class R-VI Interest interest shall be designated as the Residual Interest in REMIC VI. The Certificates (other than the Residual Certificates) shall be designated as the Regular Interests in REMIC VII and the R-VII interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any “interests” in any Trust REMIC created hereunder (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE InterestREMIC III Regular Interests, the Class P InterestREMIC IV Regular Interests, the Swap-IO Interest REMIC V Regular Interests, REMIC VI Regular Interests and REMIC VII Regular Interests and the interests represented by the Certificates.

REMIC Administration. (a) The An election will be made by the Certificate Administrator on behalf of the Trustee shall elect to treat each Trust REMIC the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Collection Account, the Reserve Accounts and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and, to the extent of the Trust’s interest therein, any related REO Properties as a REMIC under the Code and(such REMIC being herein designated as “REMIC I”), if necessary, under applicable state lawother than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Loan. Each such election Such elections will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC I I, and the REMIC I Residual Interest (which shall be evidenced by the Class R-I Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC I. The An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC II”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC II II, and the REMIC II Residual Interest (which shall be evidenced by the Class R-II Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC II. The An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC III”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Interests are issued. For purposes of such election, the Class A A-1, Class A-2, Class A-3, Class A-4, Class A-S, Class B, Class C, Class D, Class E, Class F and Class G Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE H REMIC III Regular Interest and the Class P Interest X REMIC III Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC III III, and the REMIC III Residual Interest (which shall be evidenced by the Class R-III Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee Certificate Administrator shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest Interests and the interests represented by the CertificatesREMIC III Interests.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Accounts, the Interest Reserve Account, the Distribution Account and the Reserve Account, the Insurance Policies and any related amounts REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate class of "regular interests" in REMIC I and the Class R-I Interest Certificates shall be designated as the Residual Interest sole class of "residual interests" in REMIC I. The An election will be made by the Trustee to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole class of the "residual interests" in REMIC II. The Class A Certificates, An election will be made by the Mezzanine Certificates, Trustee to treat the Swap-IO Interestsegregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class CE Interest A-1, Class A-1A, Class A-2, Class A-3, Class A-4, Class A-1A, Class A-M, Class A-J, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O, Class P, Class X and the Class P Interest X-Y Certificates shall be designated as the Regular Interests "regular interests" in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole class of "residual interests" in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VIIII. The Trustee shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest REMIC Regular Certificates and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee Certificate Administrator shall elect make elections or cause elections to be made to treat each of the Trust REMIC REMICs as a REMIC under the Code and, if necessary, under applicable state lawApplicable State and Local Tax Law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Uncertificated Regular Interests and the Certificates are issued. For the purposes of the REMIC election in respect of REMIC Ithe Upper-Tier REMIC, each Class of the REMIC I Regular Interests Certificates (exclusive of the portion of the Class NR Certificates representing an interest in the Grantor Trust) and the Class CSQ Certificates shall be designated as the Regular Interests “regular interests” (or in REMIC I the case of an exchange and conversion of Class A-S, Class B and Class C Certificates for Class EC Certificates, such “regular interests” shall be deemed to be held by the Trustee in uncertificated form unless reconverted to Class A-S, Class B and Class C Certificates) and the Class R-I UR Interest shall be designated as the Residual Interest sole class of “residual interests” in the Upper-Tier REMIC. For purposes of the REMIC I. The REMIC II Regular election in respect of the Lower-Tier REMIC, each Class of Uncertificated Lower-Tier Interests shall be designated as the Regular Interests in REMIC II a class of “regular interests” and the Class R-II LR Interest shall be designated as the Residual Interest sole class of “residual interests” in the Lower-Tier REMIC. For purposes of the REMIC II. The election in respect of the Centreville Square Mortgage Loan REMIC, each Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest of Uncertificated Centreville Square Interests shall be designated as a class of “regular interests” and the Class P CS-R Interest shall be designated as the Regular Interests sole class of “residual interests” in REMIC III and the Class R-III Interest shall be designated as Centreville Square Mortgage Loan REMIC. None of the Residual Interest in REMIC III. The CE Certificates shall be designated as Special Servicer, the Regular Interests in REMIC IV and Master Servicer nor the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) in any Trust REMIC other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest and the interests represented by the Certificatesforegoing interests.

REMIC Administration. (a) The An election will be made by the Certificate Administrator on behalf of the Trustee shall elect to treat each Trust REMIC the segregated pool of assets consisting of the Mortgage Loans (other than 367 Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Collection Account, the Reserve Accounts and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and, to the extent of the Trust’s interest therein, any related REO Properties as a REMIC under the Code and(such REMIC being herein designated as “REMIC I”), if necessary, under applicable state lawother than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Loan. Each such election Such elections will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC I I, and the REMIC I Residual Interest (which shall be evidenced by the Class R-I Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC I. The An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC II”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC II II, and the REMIC II Residual Interest (which shall be evidenced by the Class R-II Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC II. The An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC III”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Interests are issued. For purposes of such election, the Class A A-0, Xxxxx X-0, Class A-SB, Class A-0, Xxxxx X-0, Class D, Class E, Class F and Class G Certificates, the Mezzanine Certificates, the Swap-IO InterestEX XXXXX III Regular Interests, the Class CE H REMIC III Regular Interest and the Class P Interest X REMIC III Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC III III, and the REMIC III Residual Interest (which shall be evidenced by the Class R-III Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee Certificate Administrator shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest Interests and the interests represented by the CertificatesREMIC III Interests.

REMIC Administration. (a) The Trustee REMIC elections as set forth in the Preliminary Statement shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. The regular interests and residual interest in each REMIC shall be as designated in the Preliminary Statement. For the purposes of the REMIC election elections in respect of the Trust Fund, (i) the REMIC I1 Regular Interests will represent the “regular interests” in REMIC 1, the Class R-1 Interest will constitute the sole class of “residual interests” in REMIC I 1, (ii) the REMIC 2 Regular Interests shall be designated as will represent the “regular interests” in REMIC 2, the Class R-2 Interest will constitute the sole class of “residual interests” in REMIC 2, (iii) the REMIC 3 Regular Interests will represent the “regular interests” in REMIC I and 3, the Class R-I R-3 Interest shall be designated as will constitute the Residual Interest sole class of “residual interests” in REMIC I. The REMIC II Regular Interests shall be designated as 3, (iv) the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine CertificatesClass M Certificates (exclusive of any right to receive distributions from the Net WAC Rate Carryover Reserve Account in respect of the Net WAC Rate Carryover Amount or the Swap Account or any obligation to make payments to the Swap Account), the Swap-IO Class C Interest, the Class CE IO Interest and the Class P Interest shall be designated as the Regular Interests “regular interests” in REMIC III 4 and the Class R-4 Interest will constitute the sole class of “residual interests” in REMIC 4, (v) the Class C Certificates (exclusive of any obligation to make payments to the Net WAC Rate Carryover Reserve Account in respect of the Net WAC Rate Carryover Amount) will represent ownership of “regular interests” in REMIC 5 and the Class R-5 Interest will constitute the sole class of “residual interests” in REMIC 5, (vi) the Class P Certificates will represent ownership of “regular interests” in REMIC 6 and the Class R-6 Interest will constitute the sole class of “residual interests” in REMIC 6, (vii) the REMIC 7 Regular Interest SWAP IO will represent ownership of “regular interests” in REMIC 7 and the Class R-7 Interest will constitute the sole class of “residual interests” in REMIC 7, (viii) the Class R Certificates will evidence ownership of the Class R-2 Interest, Class R-3 Interest and Class R-4 Interest and (ix) the Class R-III X Certificates will evidence ownership of the Class R-5 Interest, the Class R-6 Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IVR-7 Interest. The P Certificates shall be designated as the Regular Interests in REMIC V Securities Administrator and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) in any REMIC created hereunder other than (a) the REMIC I 1 Regular Interests, the REMIC II 2 Regular Interests, the REMIC 3 Regular Interests, the REMIC 4 Regular Interests, the REMIC 5 Regular Interests, the REMIC 6 Regular Interests or the REMIC 7 Regular Interests, the ownership of which is represented by the Class CE A Certificates, the Class M Certificates, the REMIC 7 Regular Interest SWAP IO, the Class C Certificates and the Class P Certificates and (b) the Class R-2 Interest, the Class P R-3 Interest, the Swap-IO Class R-4 Interest, the Class R-5 Interest, the Class R-6 Interest and the interests represented by Class R-7 Interest. The Securities Administrator will apply for an Employee Identification Number from the Certificates.IRS via form SS-4 or any other acceptable method for each Trust REMIC

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Each such Such election will be made by the Trust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I-A, the REMIC I I-A Regular Interests shall be designated as the Regular Interests in REMIC I I-A and the Class R-IA Interest shall be designated as the Residual Interests in REMIC I-A. For the purposes of the REMIC election in respect of REMIC I-B, the Group I Certificates (other than the Class I-R Certificates) shall be designated as the Regular Interests in REMIC I-B and the Class R-IB Interest shall be designated as the Residual Interest in REMIC I. The I-B. Neither the Trustee nor the Trust Administrator shall permit the creation of any “interests” in REMIC I-A or REMIC I-B (within the meaning of Section 860G of the Code) other than the REMIC I-A Regular Interests and the Group I Certificates. For the purposes of the REMIC election in respect of REMIC II, the REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class RII-II Interest R Certificates shall be designated as the Residual Interest Interests in REMIC II. The Class A Certificates, Neither the Mezzanine Certificates, Trustee nor the Swap-IO Interest, the Class CE Interest and the Class P Interest Trust Administrator shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “interests” in any Trust REMIC II (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest Interests and the interests represented Group II Certificates. The Trustee shall elect to treat each REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Such election will be made by the CertificatesTrust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued.

REMIC Administration. (a) The Trustee Certificate Administrator shall elect make elections or cause elections to be made to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state lawApplicable State and Local Tax Law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Uncertificated Lower-Tier Interests and the Certificates are issued. For the purposes of the REMIC election in respect of REMIC Ithe Upper-Tier REMIC, each Class of the REMIC I Regular Interests Certificates shall be designated as the Regular Interests “regular interests” (or in REMIC I the case of an exchange and conversion of Class A-S, Class B and Class C Certificates for Class EC Certificates, such “regular interests” shall be deemed to be held by the Trustee in uncertificated form unless reconverted to Class A-S, Class B and Class C Certificates) and the Class R-I UR Interest shall be designated as the Residual Interest sole class of “residual interests” in the Upper-Tier REMIC. For purposes of the REMIC I. The REMIC II Regular election in respect of the Lower-Tier REMIC, each Class of Uncertificated Lower-Tier Interests shall be designated as the Regular Interests in REMIC II a class of “regular interests” and the Class R-II LR Interest shall be designated as the Residual Interest sole class of “residual interests” in the Lower-Tier REMIC. For purposes of the REMIC II. The Class A Certificates, election in respect of the Mezzanine Certificates, the SwapU-IO InterestHaul Self Storage Trust Companion Loan REMIC, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE UHP Certificates shall be designated as the Regular Interests in REMIC IV “regular interests” and an uncertificated interest represented by the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P R Certificates shall be designated as the Regular Interests sole class of “residual interests” in REMIC V and the Class RU-V Interest shall be designated as Haul Self Storage Trust Companion Loan REMIC. None of the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as Special Servicer, the Regular Interest in REMIC VI and Master Servicer nor the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) in any Trust REMIC other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest and the interests represented by the Certificatesforegoing interests.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I, the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The For the purposes of the REMIC election in respect of REMIC II, the REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A CertificatesCertificates and the Mezzanine Certificates (other than the right to receive amounts from the Net WAC Rate Carryover Reserve Account or the Swap Account or the obligation to make payments to the Swap Account), the Mezzanine Certificates, the Swap-IO Class CE-1 Interest, the Class CE CE-2 Interest, the Class P Interest and the Class P Swap-IO Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Class CE-1 Certificates shall be designated as the Regular Interests Interest in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class P Certificates shall be designated as the Regular Interests Interest in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAPSwap-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class CE-2 Certificates shall be designated as the Regular Interest in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any “"interests” " in any Trust REMIC (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest Interests and the interests represented by the Certificates.

REMIC Administration. (a) The Trustee shall elect make elections or cause elections to be made to treat each Trust of the Lower-Tier REMIC, the Middle-Tier REMIC and the Upper-Tier REMIC as a REMIC under the Code and, if necessary, under applicable state lawApplicable State and Local Tax Law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Uncertificated Lower-Tier Interests, Uncertificated Middle-Tier Interests and the Certificates are issued. For the purposes of the REMIC election in respect of REMIC Ithe Upper-Tier REMIC, each Class of the Regular Certificates (other than the Class A-2SFL Certificates and the Class A-JFL Certificates) and the Class A-2SFL Regular Interest and the Class A-JFL Regular Interest shall be designated as the "regular interests" and the Class R Certificates shall be designated as the sole class of "residual interests" in the Upper-Tier REMIC. For purposes of the REMIC I Regular election in respect of the Middle-Tier REMIC, each Class of Uncertificated Middle-Tier Interests shall be designated as the Regular Interests in REMIC I "regular interests" and the Class R-I Interest MR Certificates shall be designated as the Residual Interest sole class of "residual interests" in the Middle-Tier REMIC. For purposes of the REMIC I. The REMIC II Regular election in respect of the Lower-Tier REMIC, each Class of Uncertificated Lower-Tier Interests shall be designated as the Regular Interests in REMIC II "regular interests" and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE LR Certificates shall be designated as the Regular Interests sole class of "residual interests" in REMIC IV and the Class RLower-IV Interest shall be designated as Tier REMIC. None of the Residual Interest in REMIC IV. The P Certificates shall be designated as Special Servicer, the Regular Interests in REMIC V and Master Servicers nor the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in the Lower-Tier REMIC, the Middle-Tier REMIC or the Upper-Tier REMIC other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest and the interests represented by the Certificatesforegoing interests.

REMIC Administration. (a) The An election will be made by the Certificate Administrator on behalf of the Trustee shall elect to treat each Trust REMIC the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Collection Account, the Reserve Accounts and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and, to the extent of the Trust’s interest therein, any related REO Properties as a REMIC under the Code and(such REMIC being herein designated as “REMIC I”), if necessary, under applicable state lawother than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Loan. Each such election Such elections will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC I I, and the REMIC I Residual Interest (which shall be evidenced by the Class R-I Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC I. The An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC II”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC II II, and the REMIC II Residual Interest (which shall be evidenced by the Class R-II Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC II. The An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC III”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Interests are issued. For purposes of such election, the Class A X-0, Xxxxx X-0, Class A-SB, Class X-0, Xxxxx X-0, Class D, Class E, Class F, Class G, Class H and Class J Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest XX XXXXX III Regular Interests and the Class P Interest X REMIC III Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC III III, and the REMIC III Residual Interest (which shall be evidenced by the Class R-III Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee Certificate Administrator shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest Interests and the interests represented by the CertificatesREMIC III Interests.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account (exclusive of the Excess Interest Sub-Account), the Insurance Policies and any REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Mortgage Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole Class of "residual interests" in REMIC IV I. The Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee Paying Agent shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests and the Residual Certificates. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class CE InterestR-II Certificates shall be designated as the sole Class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class A-1, Class A-2, Class A-3, Class A-4, Class X-1 (each Class X-1 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class X-2 (each Class X-2 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O and Class P Certificates (but other than the Class P Grantor Trust Interest, ) shall be designated as the Swap-IO Interest "regular interests" in REMIC III and the interests represented by Class R-III Certificates shall be designated as the Certificatessole Class of "residual interests" in REMIC III.

REMIC Administration. (a) The An election will be made by the Certificate Administrator on behalf of the Trustee shall elect to treat each Trust REMIC the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Collection Account, the Reserve Accounts and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and, to the extent of the Trust’s interest therein, any related REO Properties as a REMIC under the Code and(such REMIC being herein designated as “REMIC I”), if necessary, under applicable state lawother than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Loan. Each such election Such elections will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC I I, and the REMIC I Residual Interest (which shall be evidenced by the Class R-I Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC I. The An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC II”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC II II, and the REMIC II Residual Interest (which shall be evidenced by the Class R-II Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC II. The An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC III”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Interests are issued. For purposes of such election, the Class A A-1, Class A-2, Class A-3, Class A-4, Class A-J, Class B, Class C, Class D, Class E, Class F and Class G Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE H REMIC III Regular Interest and the Class P Interest X REMIC III Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC III III, and the REMIC III Residual Interest (which shall be evidenced by the Class R-III Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee Certificate Administrator shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest Interests and the interests represented by the CertificatesREMIC III Interests.

REMIC Administration. (a) The Trustee Paying Agent shall elect make elections or cause elections to be made to treat each Trust of the Lower-Tier REMIC, the Middle-Tier REMIC and the Upper-Tier REMIC as a REMIC under the Code and, if necessary, under applicable state lawApplicable State and Local Tax Law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Uncertificated Lower-Tier Interests, Uncertificated Middle-Tier Interests and the Certificates are issued. For the purposes of the REMIC election in respect of REMIC Ithe Upper-Tier REMIC, each Class of the Regular Certificates (other than the Class A-2SFL Certificates and the Class A-3SFL Certificates) and the Class A-2SFL Regular Interest and the Class A-3SFL Regular Interest shall be designated as the "regular interests" and the Class R Certificates shall be designated as the sole class of "residual interests" in the Upper-Tier REMIC. For purposes of the REMIC I Regular election in respect of the Middle-Tier REMIC, each Class of Uncertificated Middle-Tier Interests shall be designated as the Regular Interests in REMIC I "regular interests" and the Class R-I Interest MR Certificates shall be designated as the Residual Interest sole class of "residual interests" in the Middle-Tier REMIC. For purposes of the REMIC I. The REMIC II Regular election in respect of the Lower-Tier REMIC, each Class of Uncertificated Lower-Tier Interests shall be designated as the Regular Interests in REMIC II "regular interests" and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE LR Certificates shall be designated as the Regular Interests sole class of "residual interests" in REMIC IV and the Class RLower-IV Interest shall be designated as Tier REMIC. None of the Residual Interest in REMIC IV. The P Certificates shall be designated as Special Servicer, the Regular Interests in REMIC V and Master Servicers, the Class R-V Interest shall be designated as Paying Agent nor the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in the Lower-Tier REMIC, the Middle-Tier REMIC or the Upper-Tier REMIC other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest and the interests represented by the Certificatesforegoing interests.

REMIC Administration. (a) The An election will be made by the Certificate Administrator on behalf of the Trustee shall elect to treat each Trust REMIC the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Collection Account, the Reserve Accounts and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and, to the extent of the Trust’s interest therein, any related REO Properties as a REMIC under the Code and(such REMIC being herein designated as “REMIC I”), if necessary, under applicable state lawother than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Loan. Each such election Such elections will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC I I, and the REMIC I Residual Interest (which shall be evidenced by the Class R-I Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC I. The An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC II”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC II II, and the REMIC II Residual Interest (which shall be evidenced by the Class R-II Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC II. The An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC III”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Interests are issued. For purposes of such election, the Class A A-1, Class A-2, Class A-0, Xxxxx X-0, Class D, Class E, Class F, Class G and Class H Certificates, the Mezzanine Certificates, the Swap-IO Class J REMIC III Regular Interest, the Class CE Interest PST REMIC III Regular Interests and the Class P Interest X REMIC III Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC III III, and the REMIC III Residual Interest (which shall be evidenced by the Class R-III Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee Certificate Administrator shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest Interests and the interests represented by the CertificatesREMIC III Interests.

REMIC Administration. (a) The An election will be made by the Certificate Administrator on behalf of the Trustee shall elect to treat each Trust REMIC the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Collection Account, the Reserve Accounts and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and, to the extent of the Trust’s interest therein, any related REO Properties as a REMIC under the Code and(such REMIC being herein designated as “REMIC I”), if necessary, under applicable state lawother than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Loan. Each such election Such elections will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC I I, and the REMIC I Residual Interest (which shall be evidenced by the Class R-I Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC I. The An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC II”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC II II, and the REMIC II Residual Interest (which shall be evidenced by the Class R-II Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC II. The An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC III”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Interests are issued. For purposes of such election, the Class A A-1, Class A-2, Class A-3, Xxxxx X-0, Xlass D, Class E, Class F, Class G and Class H Certificates, the Mezzanine Certificates, the Swap-IO InterestEC Trust REMIC III Regular Interests, the Class CE J REMIC III Regular Interest and the Class P Interest X REMIC III Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC III III, and the REMIC III Residual Interest (which shall be evidenced by the Class R-III Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee Certificate Administrator shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest Interests and the interests represented by the CertificatesREMIC III Interests.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account, the Insurance Policies and any REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note and Companion Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole Class of "residual interests" in REMIC IV I. The Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee Paying Agent shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests and the Residual Certificates. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class CE InterestR-II Certificates shall be designated as the sole Class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class P InterestA-1, Class A-2, Class X-1 (each Class X-1 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Swap-IO Interest Preliminary Statement), Class X-2 (each Class X-2 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N and Class O Certificates shall be designated as the "regular interests" in REMIC III and the interests represented by Class R-III Certificates shall be designated as the Certificatessole Class of "residual interests" in REMIC III.

REMIC Administration. (a) The Trustee REMIC elections as set forth in the Preliminary Statement shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form Forms 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. The regular interests and residual interest in each REMIC shall be as designated in the Preliminary Statement. For the purposes of the REMIC election in respect of REMIC Isuch designations, the REMIC I Regular Interests interest rate of any regular interest that is computed by taking into account the weighted average of the Net Mortgage Rates of the Mortgage Loans shall be designated as reduced by the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation amount of any expense paid by the Trust to the extent that (i) such expense was not taken into account in computing the Net Mortgage Rate of any Mortgage Loan, (ii) such expense does not constitute an “interestsunanticipated expense” in any Trust of a REMIC (within the meaning of Treasury Regulation Section 860G 1.860G-1(b)(3)(ii) and (iii) the amount of such expense was not taken into account in computing the interest rate of a more junior Class of regular interests. The Closing Date is hereby designated as the “Startup Day” of each REMIC within the meaning of section 860G(a)(9) of the Code. The latest possible maturity date for purposes of Treasury Regulation 1.860G-1(a)(4) will be the Latest Possible Maturity Date. The Securities Administrator shall pay any and all tax related expenses (not including taxes) of each REMIC, including but not limited to any professional fees or expenses related to audits or any administrative or judicial proceedings with respect to such REMIC that involve the Internal Revenue Service or state tax authorities, but only to the extent that (i) such expenses are ordinary or routine expenses, including expenses of a routine audit but not expenses of litigation (except as described in (ii)); or (ii) such expenses or liabilities (including taxes and penalties) are attributable to the negligence or willful misconduct of the Securities Administrator in fulfilling its duties hereunder (including its duties as tax return preparer). The Securities Administrator shall be entitled to reimbursement of expenses to the extent provided in clause (i) above from the Securities Administration Account, provided, however, the Securities Administrator shall not be entitled to reimbursement for expenses incurred in connection with the preparation of tax returns and other reports as required by this Agreement. The Securities Administrator shall prepare, the Trustee shall sign and the Securities Administrator shall file, all of each REMIC’s federal and appropriate state tax and information returns as such REMIC’s direct representative. The expenses of preparing and filing such returns shall be borne by the Securities Administrator. The Securities Administrator or its designee shall perform on behalf of each REMIC all reporting and other tax compliance duties that are the responsibility of such REMIC under the Code, the REMIC Provisions, or other compliance guidance issued by the Internal Revenue Service or any state or local taxing authority. Among its other duties, if required by the Code, the REMIC Provisions, or other such guidance, the Securities Administrator shall provide (i) to the Treasury or other governmental authority such information as is necessary for the application of any tax relating to the transfer of a Residual Certificate to any disqualified person or organization pursuant to Treasury Regulation 1.860E-2(a)(5) and any person designated in Section 860E(e)(3) of the Code and (ii) to the Trustee such information as is necessary for the Trustee to provide to the Certificateholders such information or reports as are required by the Code or REMIC Provisions. The Trustee, the Securities Administrator, the Master Servicer and the Holders of Certificates shall take any action or cause any REMIC to take any action necessary to create or maintain the status of any REMIC as a REMIC under the REMIC Provisions and shall assist each other as necessary to create or maintain such status. None of the Trustee, the Securities Administrator, the Master Servicer and the Holder of any Residual Certificate shall knowingly take any action, cause any REMIC to take any action or fail to take (or fail to cause to be taken) any action that, under the REMIC Provisions, if taken or not taken, as the case may be, could result in an Adverse REMIC Event unless the Trustee, the Securities Administrator and the Master Servicer have received an Opinion of Counsel addressed to the Trustee (at the expense of the party seeking to take such action) to the effect that the contemplated action will not result in an Adverse REMIC Event. In addition, prior to taking any action with respect to any REMIC or the assets therein, or causing any REMIC to take any action, which is not expressly permitted under the terms of this Agreement, any Holder of a Residual Certificate will consult with the Trustee, the Securities Administrator, the Master Servicer or their respective designees, in writing, with respect to whether such action could cause an Adverse REMIC Event to occur with respect to any REMIC, and no such Person shall take any such action or cause any REMIC to take any such action as to which the Trustee, the Securities Administrator or the Master Servicer has advised it in writing that an Adverse REMIC Event could occur. Each Holder of a Residual Certificate shall pay when due any and all taxes imposed on the related REMIC by federal or state governmental authorities. To the extent that such taxes are not paid by a Residual Certificateholder, the Trustee shall pay any remaining REMIC taxes out of current or future amounts otherwise distributable to the Holder of the Residual Certificate in any such REMIC or, if no such amounts are available, out of other amounts held in the Collection Account, and shall reduce amounts otherwise payable to holders of regular interests in any such REMIC, as the case may be. The Securities Administrator shall, for federal income tax purposes, maintain books and records with respect to each REMIC on a calendar year and on an accrual basis. No additional contributions of assets after the Startup Day shall be made to any REMIC, except as expressly provided in this Agreement. Neither the Securities Administrator nor the Master Servicer shall enter into any arrangement by which any REMIC will receive a fee or other compensation for services. On or before October 15 of each calendar year beginning in 2006, the Securities Administrator shall deliver to the Trustee an Officer’s Certificate stating, without regard to any actions taken by any party other than the REMIC I Regular InterestsSecurities Administrator, the REMIC II Regular InterestsSecurities Administrator’s compliance with provisions of this Section 11.01. Notwithstanding the priority and sources of payments set forth in Article VI hereof or otherwise, the Class CE Interest, Securities Administrator shall account for all distributions on the Class P Interest, the Swap-IO Interest and the interests represented by the CertificatesCertificates as set forth in this Section 11.01.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in a Certificate Account, the Reserve Account, the Interest Reserve Account and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Mortgage Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest Certificates shall be designated as the Residual Interest sole Class of "residual interests" in REMIC I. The An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole Class of the "residual interests" in REMIC II. The Class A Certificates, An election will be made by the Mezzanine Certificates, Paying Agent to treat the Swap-IO Interestsegregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class CE Interest A-1, Class X-0X, Xxxxx X-0X, Xxxxx X-0X, Class A-AB, Class A-3, Class X-0X, Xxxxx X-0X, Xxxxx X-X, Class X-1, Class X-2, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O, Class P, Class Q and the Class P Interest S Certificates shall be designated as the Regular Interests "regular interests" in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole Class of "residual interests" in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VIIII. The Trustee and the Paying Agent shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest REMIC III Regular Interests and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Majority Mortgage Loans, the Mall at Millenia Pari Passu Loan REMIC Regular Interest, such amounts related to the Majority Mortgage Loans as shall from time to time be held in the Certificate Account and the Interest Reserve Account, such amounts related to the Majority Mortgage Loans and the Mall at Millenia Pari Passu Loan REMIC Regular Interest as shall from time to time be held in the Distribution Account, the related Insurance Policies and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Mortgage Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-REMIC I Residual Interest shall be designated as the Residual Interest sole Class of "residual interests" in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests and the Residual Certificates. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class CE InterestR-II Certificates shall be designated as the sole Class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class A-1, Class A-2, Class A-3, Class A-4, Class A-5, Class A-6, Class A-7, Class X-1, Class X-2, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O, Class P and Class Q Certificates shall be designated as the "regular interests" in REMIC III and the Class R-III Certificates shall be designated as the sole Class of "residual interests" in REMIC III. The Paying Agent shall not permit the creation of any "interests" (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the Mall at Millenia Pari Passu Loan REMIC Regular Interest, REMIC I Regular Interests, the Swap-IO Interest REMIC II Regular Interests, the REMIC III Regular Interests and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee Trust Administrator shall elect to treat each Trust REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Each such Such election will be made by the Trust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I, the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A CertificatesFloating Rate Certificates (exclusive of any right to receive distributions from or obligation to make payments to the Net WAC Rate Carryover Reserve Account in respect of the Net WAC Rate Carryover Amount or the Swap Account), the Mezzanine Certificates, the Swap-IO Class CE Interest, the Class CE IO Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class CE Certificates (exclusive of any right to receive distributions from or obligation to make payments to the Net WAC Rate Carryover Reserve Account in respect of the Net WAC Rate Carryover Amount or the Swap Account) shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-SWAP IO shall be designated as the Regular Interest Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Neither the Trustee nor the Trust Administrator shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest Interests and the interests represented by the Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Account, the Interest Reserve Account, the Reserve Account and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Mortgage Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest Certificates shall be designated as the Residual Interest sole Class of "residual interests" in REMIC I. The An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests "regular interests" in REMIC II and the Class R-II Certificates shall be designated as the sole Class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates and Class A-4FL Certificates are issued. For purposes of such election, the Class A-1, Class A-2, Class A-3, Class A-AB, Class A-4, Class A-J, Class X, Class B, Claxx X, Xxxxx X, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O and Class P Certificates (but other than the Class P Grantor Trust Interest) and the Class A-4FL Regular Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests "regular interests" in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole Class of "residual interests" in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VIIII. The Trustee and the Paying Agent shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest REMIC III Regular Interests and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account, the Insurance Policies and any REO Properties as a REMIC under the Code, other than any portion of the foregoing amounts allocable to a Companion Loan. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole class of "residual interests" in REMIC IV I. The Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee Paying Agent shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC Regular Certificates and the Residual Certificates. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interest is issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class CE InterestR-II Certificates shall be designated as the sole class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class P InterestA-1, Class A-2, Class A-3, Class A-4, Class X-1, Class X-2, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M and Class N Certificates shall be designated as the Swap-IO Interest "regular interests" in REMIC III and the interests represented by Class R-III Certificates shall be designated as the Certificatessole class of "residual interests" in REMIC III.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account, the Insurance Policies and any REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Mortgage Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole Class of "residual interests" in REMIC IV I. The Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee Paying Agent shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests and the Residual Certificates. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class CE InterestR-II Certificates shall be designated as the sole Class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class P InterestA-1, Class A-2, Class A-3, Class A-4, Class X-1 (each Class X-1 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Swap-IO Interest Preliminary Statement), Class X-2 (each Class X-2 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N and Class O Certificates shall be designated as the "regular interests" in REMIC III and the interests represented by Class R-III Certificates shall be designated as the Certificatessole Class of "residual interests" in REMIC III.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Accounts, the Interest Reserve Account, the Distribution Account and the Reserve Account, the Insurance Policies and any related amounts REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing allocable to a Serviced Companion Loan. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate class of "regular interests" in REMIC I and the Class R-I Interest Certificates shall be designated as the Residual Interest sole class of "residual interests" in REMIC I. The An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests "regular interests" in REMIC II and the Class R-II Certificates shall be designated as the sole class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates and the Class A-MFL Regular Interest are issued. For purposes of such election, the Class A-1, Class A-1A, Class A-2, Class A-NM, Class A-3, Class A-AB, Class A-4, Class A-1A, Class A-M, Class A-J, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O, Class P, Class Q, Class S, Class X-1, Class X-2 and Class X-W Certificates and the Class A-MFL Regular Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests "regular interests" in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole class of "residual interests" in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VIIII. The Trustee and the Paying Agent shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE InterestREMIC Regular Certificates, the Class P Interest, the SwapA-IO MFL Regular Interest and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will shall be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I, (i) the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The I, (ii) the REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, (iii) the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest REMIC III Regular Interests shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates , (iv) the REMIC IV Regular Interests shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The , (v) the Class A Certificates, the Mezzanine Certificates (exclusive of the right to receive payments from the Net WAC Carryover Reserve Account or the Swap Account or the obligation to make payments to the Swap Account), the Class SWAP-IO Interest, the Class A-2B1 Swap-IO Interest, the Class CE Interest and the Class P Certificates Interest shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO IV, (vi) the Class CE Certificates shall be designated as the Regular Interest Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI, (vii) the Class P Certificates shall be designated as the Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII, (viii) REMIC VIII Regular Interest SWAP-IO shall be designated as the Regular Interests in REMIC VIII and the Class R-VIII Interest shall be designated as the Residual Interest in REMIC VIII and (ix) REMIC IX Regular Interest Class A-2B1 Swap-IO shall be designated as the Regular Interests in REMIC IX and the Class R-IX Interest shall be designated as the Residual Interest in REMIC IX. The Trustee shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests, the REMIC IV Regular Interests, the Class CE Interest, the Class P Interest, the Class SWAP-IO Interest, the Class A-2B1 Swap-IO Interest and the interests represented by the Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I, the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The REMIC II Regular Interests Class A Certificates, the Class M-1 Certificates, the Class M-2 Interest, the Class M-3 Interest, the Class M-4 Interest, the Class M-5 Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest M-2 Certificates shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Class M-3 Certificates shall be designated as the Regular Interests in REMIC IV VI and the Class R-IV VI Interest shall be designated as the Residual Interest in REMIC IVVI. The P Class M-4 Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO The Class M-5 Certificates shall be designated as the Regular Interest Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class CE Certificates shall be designated as the Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Class P Certificates shall be designated as the Regular Interests in REMIC VIII and the Class R-VIII Interest shall be designated as the Residual Interest in REMIC VIII. The Trustee shall not permit the creation of any “"interests” " in any Trust REMIC (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest Interests and the interests represented by the Certificates.

REMIC Administration. (a) The Trustee Paying Agent shall elect make elections or cause elections to be made to treat each Trust of the Loan REMIC, the Lower-Tier REMIC and the Upper-Tier REMIC as a REMIC under the Code and, if necessary, under applicable state lawApplicable State and Local Tax Law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Uncertificated Lower-Tier Interests and the Certificates are issued. For the purposes of the REMIC election in respect of REMIC Ithe Upper-Tier REMIC, each Class of the Regular Certificates and the Class PS Certificates shall be designated as the "regular interests" (in the case of the Class NR Certificates, exclusive of the portion thereof, representing the right to Excess Interest and Amounts in the Excess Interest Distribution Account) and the Class R Certificates shall be designated as the sole class of "residual interests" in the Upper-Tier REMIC. For purposes of the REMIC I election in respect of the Lower-Tier REMIC, each Class of Uncertificated Lower-Tier Interests shall be designated as the "regular interests" and the Class LR Certificates shall be designated as the sole class of "residual interests" in the Lower-Tier REMIC. For purposes of the REMIC election in respect of the Loan REMIC, each Class of Loan REMIC Regular Interests shall be designated as the Regular Interests in REMIC I "regular interests" and the Loan REMIC Residual Interest, represented by the Class R-I Interest LR Certificates, shall be designated as the Residual Interest sole class of "residual interests" in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and Loan REMIC. None of the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A CertificatesSpecial Servicer, the Mezzanine CertificatesServicer, the Swap-IO Interest, Paying Agent nor the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in the Loan REMIC, the Lower-Tier REMIC or the Upper-Tier REMIC other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest and the interests represented by the Certificatesforegoing interests.

REMIC Administration. (a) The An election will be made by the Certificate Administrator on behalf of the Trustee shall elect to treat each Trust REMIC the segregated pool of assets consisting of the Mortgage Loans (other than any Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Collection Account, the Reserve Accounts and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and, to the extent of the Trust’s interest therein, any related REO Properties as a REMIC under the Code and(such REMIC being herein designated as “REMIC I”), if necessary, under applicable state lawother than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Loan. Each such election Such elections will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC I I, and the REMIC I Residual Interest (which shall be evidenced by the Class R-I Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC I. The An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC II”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC II II, and the REMIC II Residual Interest (which shall be evidenced by the Class R-II Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC II. The An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC III”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Interests are issued. For purposes of such election, the Class A A-1, Class A-2, Class A-SB, Class A-3, Class A-4, Class D, Class E, Class F, Class G and Class H Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest EC Trust REMIC III Regular Interests and the Class P Interest X REMIC III Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC III III, and the REMIC III Residual Interest (which shall be evidenced by the Class R-III Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee Certificate Administrator shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest Interests and the interests represented by the CertificatesREMIC III Interests.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will shall be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I, (i) the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The I, (ii) the REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The , (iii) the Class A Certificates, the Mezzanine CertificatesCertificates (exclusive of the right to receive payments from the Net WAC Carryover Reserve Account or the Swap Account or the obligation to make payments to the Swap Account), the SwapClass SWAP-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The , (v) the Class CE Certificates shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The , (vi) the Class P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. V and (vii) REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the SwapClass SWAP-IO Interest and the interests represented by the Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Each such Such election will be made by the Trust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I-A, the REMIC I I-A Regular Interests shall be designated as the Regular Interests in REMIC I I-A and the Class R-I IA Residual Interest shall be designated as the Residual Interest Interests in REMIC I. The I-A. For the purposes of the REMIC II election in respect of REMIC I-B, the REMIC I-B Regular Interests shall be designated as the Regular Interests in REMIC II I-B and the Class R-II IB Residual Interest shall be designated as the Residual Interests in REMIC I-B. For the purposes of the REMIC election in respect of REMIC I-C, the Group 1 Certificates or Components thereof (other than the Class 1-R Certificates), shall be designated as the Regular Interests in REMIC I-C and the Class R-IC Residual Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, I-C. Neither the Mezzanine Certificates, Trustee nor the Swap-IO Interest, the Class CE Interest and the Class P Interest Trust Administrator shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “interests” in any Trust REMIC I-A, REMIC I-B or REMIC I-C (within the meaning of Section 860G of the Code) other than the REMIC I I-A Regular Interests, REMIC I-B Regular Interests and the Group 1 Certificates. For the purposes of the REMIC election in respect of REMIC II-A, the REMIC II-A Regular Interests shall be designated as the Regular Interests in REMIC II-A and the Class R-IIA Residual Interest shall be designated as the Residual Interests in REMIC II-A. For the purposes of the REMIC election in respect of REMIC II-B, the REMIC II-B Regular Interests shall be designated as the Regular Interests in REMIC II-B and the Class R-IIB Residual Interest shall be designated as the Residual Interests in REMIC II-B. For the purposes of the REMIC election in respect of REMIC II-C, the Group 1 Certificates or Components thereof (other than the Class 2-R Certificates), shall be designated as the Regular Interests in REMIC II-C and the Class R-IIC Residual Interest shall be designated as the Residual Interest in REMIC II-C. Neither the Trustee nor the Trust Administrator shall permit the creation of any “interests” in REMIC II-A, REMIC II-B or REMIC II-C (within the meaning of Section 860G of the Code) other than the REMIC II-A Regular Interests, the REMIC II II-B Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest Interests and the interests represented Group 2 Certificates. The Trustee shall elect to treat each REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Such election will be made by the CertificatesTrust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Trustee to treat the segregated pool of assets consisting of the REMIC Mortgage Loans, such amounts as shall from time to time be held in the Collection Account and the Distribution Account in respect thereof (other than any amounts attributable to Non-REMIC Assets or Non-REMIC Fees), the Insurance Policies (to the extent related to the REMIC Mortgage Loans) and any REO Properties acquired in connection with servicing a REMIC Mortgage Loan as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the forty REMIC I Regular Interests shall be (each of which corresponds to and represents beneficial ownership of a separate REMIC Mortgage Loan) each is designated as the Regular Interests a separate class of "regular interests" in REMIC I and the Class R-I Interest shall be is designated as the Residual Interest sole class of "residual interests" in REMIC I. The An election will be made by the Trustee to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, each of the REMIC II Regular Interests shall be (consisting of the Class A-1A Regular Interests, the Class A-1B Regular Interests, the Class A-2 Regular Interests, the Class B Regular Interests, the Class C Regular Interests, the Class D Regular Interests, the Class E Regular Interests, the Class F Regular Interests, the Class G Regular Interests, the Class H Regular Interests, the Class J Regular Interests, the Class K Regular Interests and the Class L Regular Interests) is designated as the Regular Interests a separate class of "regular interests" in REMIC II and the Class R-II Interest shall be is designated as the Residual Interest sole class of "residual interests" in REMIC II. The Class A Certificates, An election will be made by the Mezzanine Certificates, Trustee to treat the Swap-IO Interestsegregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class CE Interest A-1A, Class X-0X, Xxxxx X-0, Class IO, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K and the Class P Interest shall be L Certificates are designated as the Regular Interests "regular interests" in REMIC III and the Class R-III Interest shall be is designated as the Residual Interest sole class of "residual interests" in REMIC III. The CE Certificates shall be designated as Class R-I Interest, the Regular Interests in REMIC IV Class R-II Interest and the Class R-IV III Interest initially shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and represented by the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VIR Certificate. The Trustee shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest Interests and the interests represented evidenced by the CertificatesREMIC III Certificates and the Class R Certificate.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account, the Insurance Policies and any REO Properties as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as a separate class of "regular interests" in the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole class of "residual interests" in the REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. I. The Trustee shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I, REMIC II and REMIC III Regular Interests and the Residual Certificates. An election will be made by the Trustee to treat the segregated pool of assets consisting of the REMIC I Regular InterestsInterests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interest is issued. For the purposes of such election, the REMIC II Regular InterestsInterests shall be designated as the "regular interests" in REMIC II and the Class R-II Certificates shall be designated as the sole class of the "residual interests" in REMIC II. An election will be made by the Trustee to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class CE InterestX-0, Xxxxx X-0, Class X, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O and Class P Certificates shall be designated as the "regular interests" in REMIC III and the Class P Interest, R-III Certificates shall be designated as the Swap-IO Interest and the interests represented by the Certificatessole class of "residual interests" in REMIC III.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Trustee on behalf of the Trust to treat the segregated pool of assets consisting of the Mortgage Loans (other than the right to Excess Interest in respect of the Anticipated Repayment Date Loans), such amounts as shall from time to time be held in the Collection Account and the Distribution Account in respect thereof, the Insurance Policies and any REO Properties and any other assets constituting REMIC I (as set forth on the definition of REMIC I) as 151 a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect such election, each of REMIC I, the REMIC I Regular Interests shall be designated as the Regular Interests a separate class of "regular interests" in REMIC I and the Class R-I Interest Certificates shall be designated as the Residual Interest sole class of "residual interests" in REMIC I. The An election will be made by the Trustee on behalf of REMIC II to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole class of "residual interests" in REMIC II. The An election will be made by the Trustee on behalf of REMIC III to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class A A-1, Class A-2, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, and Class N Certificates, the Mezzanine Class O Regular Interest represented by the Class O Certificates, the Swap-IO Interest, and each Component Interest of the Class CE Interest and the Class P Interest X Certificates shall be designated as the Regular Interests "regular interests" in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole class of "residual interests" in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VIIII. The Trustee shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Treasury regulation Section 860G 1.860D-1(b)(1)) in any of the Code) REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest Interests and the interests represented evidenced by the Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each that the Trust REMIC Fund (other than the Initial Interest Coverage Account, the Funding Account, and the Basis Risk Reserve Fund) be treated as a REMIC under the Code and, if necessary, under three separate REMICs for federal and any applicable state lawand local income tax purposes. Each such election The assets of REMIC 1 will consist of all of the assets constituting the Trust Estate Fund other than the Basis Risk Reserve Fund and rights of the Holders of the Class A Certificates and Class X Certificates to distributions there from REMIC 1 will issue classes of interests which will be made by the REMIC 1 Regular Interests (which will be uncertificated and will represent the "regular interests" in REMIC 1) and the Class R2 Interest, which will be the sole class of "residual interests" in REMIC 1. The Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return will hold the REMIC 1 Regular Interests in trust for the taxable year ending on the last day benefit of the calendar year in which the Certificates are issuedREMIC 2. For the purposes The assets of REMIC 2 will consist of the REMIC election in respect 1 Regular Interests. REMIC 2 will issue classes of REMIC Iinterests, which will be the REMIC I 2 Regular Interests shall (which will be designated as uncertificated and will represent the Regular Interests "regular interests" in REMIC I 2) and the Class R-I Interest shall R3 Interest, which will be designated as the Residual Interest sole class of "residual interests" in REMIC I. 2. The assets of REMIC II 3 will consist of the REMIC 2 Regular Interests shall be designated as Interests. REMIC 3 will issue the Regular Interests Class A and Class X (which except for the Class A Certificates' rights to Excess Basis Risk Shortfall will represent the "regular interests" in REMIC II 3) and the Class R-II Interest shall R1 Interest, which will be designated as the Residual Interest sole class of "residual interests" in REMIC II3. The Class A Certificates, R Certificates will represent beneficial ownership of the Mezzanine Certificates, the Swap-IO Class R1 Interest, Class R2 Interest and Class R3 Interest. The Owner of the Class CE R Certificate representing the Tax Matters Person Residual Interest and is hereby designated at any time the largest Percentage Interest in the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE R Certificates shall be designated the "tax matters person" as defined in the Regular Interests in REMIC IV Provisions (the "Tax Matters Person") with respect to each of REMIC 1, REMIC 2 and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI3. The Trustee shall not permit treat the creation Class A Certificates as a regular interest with a principal balance equal to the sum of the outstanding Certificate Principal Balance for the Class A Certificates for such Distribution Date plus the outstanding amount of REMIC Basis Risk Shortfalls for such Distribution Date. The Trustee shall treat the Class A Certificateholders' rights to receive payments of Excess Basis Risk Shortfall as an interest rate cap agreement (the "Cap Agreement") that the Trustee holds separate and apart from the portion of the Class A Certificates treated as a REMIC regular interest and shall treat the Class A Certificateholders as owning the portion of the Class A Certificate treated as a REMIC regular interest issued by REMIC 3 and the Cap Agreement through a trust treated as a grantor trust under subpart E of part 1 of subchapter J of Chapter 1 of subtitle A of the Code. The Trustee shall treat the Cap Agreement as having a value of $10,000 for purposes of determining the issue price of the regular interests issued by each REMIC and calculating the income of Class A Certificateholders under the Cap Agreement. Notwithstanding any “interests” in any Trust REMIC (other provision of this Agreement, the Basis Risk Reserve Fund shall be treated as an outside reserve fund within the meaning of Section 860G Treasury regulation section 1.860G-2(h) and not an asset of any REMIC created pursuant to this Agreement, the owners of the CodeBasis Risk Reserve Fund shall be the owner(s) other than the REMIC I Regular Interests, the REMIC II Regular Interests, of the Class CE InterestX Certificates, and for all federal tax purposes, amounts transferred by REMIC 3 to the Basis Risk Reserve Fund shall be treated as distributed by REMIC 3 to the owner(s) of the Class P Interest, X Certificates and owners of the Swap-IO Interest and Class 125 X Certificates shall include as income their pro rata share of the income of such fund including income from the regular interests ownership of which is represented by the Class X Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Account, the Interest Reserve Account, the Reserve Account and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Mortgage Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest Certificates shall be designated as the Residual Interest sole Class of "residual interests" in REMIC I. The An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole Class of the "residual interests" in REMIC II. The Class A Certificates, An election will be made by the Mezzanine Certificates, Paying Agent to treat the Swap-IO Interestsegregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class CE Interest A-1, Class A-1A, Class A-2, Class A-AB, Class A-3, Class A-M, Class A-J, Class X, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O and Class P Certificates (but other than the Class P Interest Grantor Trust Interest) shall be designated as the Regular Interests "regular interests" in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole Class of "residual interests" in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VIIII. The Trustee and the Paying Agent shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest REMIC III Regular Interests and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Trustee Paying Agent to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account, the Insurance Policies and any REO Properties as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as a separate class of "regular interests" in the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole class of "residual interests" in the REMIC IV and I. Neither the Class R-IV Interest Trustee nor the Paying Agent shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I, REMIC II and REMIC III Regular Interests and the Residual Certificates. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular InterestsInterests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interest is issued. For the purposes of such election, the REMIC II Regular InterestsInterests shall be designated as the "regular interests" in REMIC II and the Class R-II Certificates shall be designated as the sole class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class CE InterestA-1, Xxxxx X-0, Xxass X, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, and Class N Certificates, together with the REMIC III Class P Interest, the Swap-IO O Regular Interest and the interests represented by REMIC III Excess Interest, shall be designated as the Certificates"regular interests" in REMIC III and the Class R-III Certificates shall be designated as the sole class of "residual interests" in REMIC III.

REMIC Administration. (a) The Trustee Trust Administrator shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee Trust Administrator on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I, the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The REMIC II Regular Interests Class A Certificates, the Class M-1 Certificates, the Class M-2 Certificates, the Class M-3 Certificates (exclusive of any right to receive payments from the Net WAC Rate Carryover Account), the Class M-4 Interest, the Class M-5 Interest, the Class M-6 Interest, the Class M-7 Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, M-4 Certificates (exclusive of any right to receive payments from the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest Net WAC Rate Carryover Account) shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Class M-5 Certificates (exclusive of any right to receive payments from the Net WAC Rate Carryover Account) shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Class M-6 Certificates (exclusive of any right to receive payments from the Net WAC Rate Carryover Account) shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO The Class M-7 Certificates (exclusive of any right to receive payments from the Net WAC Rate Carryover Account) shall be designated as the Regular Interest Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class CE Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Class P Certificates shall be designated as Regular Interests in REMIC VIII and the Class R-VIII Interest shall be designated as the Residual Interest in REMIC VIII. Neither the Trustee nor the Trust Administrator shall not permit the creation of any “"interests” " in any Trust REMIC (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest Interests and the interests represented by the CertificatesResidual Interests named above.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account, the Insurance Policies and any REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole Class of "residual interests" in REMIC IV I. The Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee Paying Agent shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests and the Residual Certificates. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class CE InterestR-II Certificates shall be designated as the sole Class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class P InterestA-1, Class A-2, Class X-1 (each Class X-1 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Swap-IO Interest Preliminary Statement), Class X-2 (each Class X-2 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N and Class O Certificates shall be designated as the "regular interests" in REMIC III and the interests represented by Class R-III Certificates shall be designated as the Certificatessole Class of "residual interests" in REMIC III.

REMIC Administration. (a) The Trustee Trust Administrator shall elect to treat each Trust REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. The Trust Administrator shall elect to treat the segregated pool of assets consisting of the portion of the Trust Fund related to the Pool I Mortgage Loans (exclusive of the Interest Coverage Account, Pool I Swap Agreement, the Pool I Swap Account and the Pool I Net WAC Rate Carryover Reserve Account and any Servicer Prepayment Payment Amounts) as a REMIC for federal income tax purposes, and such segregated pool of assets will be designated as “REMIC I.” For the purposes of the REMIC election in respect of REMIC I, the REMIC I Regular Interests shall be designated as the Regular Interests regular interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest residual interest in REMIC I. The Trust Administrator shall elect to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC for federal income tax purposes and such segregated pool of assets shall be designated as “REMIC II.” For the purposes of the REMIC election in respect of REMIC II, the REMIC II Regular Interests shall be designated as the Regular Interests regular interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest residual interest in REMIC II. The Class A CertificatesTrust Administrator shall elect to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC for federal income tax purposes and such segregated pool of assets shall be designated as “REMIC III.” For the purposes of the REMIC election in respect of REMIC III, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest REMIC III Regular Interests shall be designated as the Regular Interests regular interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest residual interest in REMIC III. The CE Certificates Trust Administrator shall elect to treat the segregated pool of assets consisting of the portion of the Trust Fund related to the Pool II Mortgage Loans (exclusive of the Interest Coverage Account, Pool II Swap Agreement, the Pool II Swap Account and the Pool II Net WAC Rate Carryover Reserve Account and any Servicer Prepayment Payment Amounts) as a REMIC for federal income tax purposes, and such segregated pool of assets will be designated as “REMIC IV.” For the purposes of the REMIC election in respect of REMIC IV, the REMIC IV Regular Interests shall be designated as the Regular Interests regular interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest residual interests in REMIC IV. The P Certificates Trust Administrator shall elect to treat the segregated pool of assets consisting of the REMIC IV Regular Interests as a REMIC for federal income tax purposes, and such segregated pool of assets shall be designated as “REMIC V.” For the purposes of the REMIC election in respect of REMIC V, the REMIC V Regular Interests shall be designated as the Regular Interests regular interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest residual interest in REMIC V. The Trust Administrator shall elect to treat the segregated pool of assets consisting of the REMIC V Regular Interests as a REMIC for federal income tax purposes, and such segregated pool of assets shall be designated as “REMIC VI.” For the purposes of the REMIC election in respect of REMIC VI, the REMIC VI Regular Interest SWAP-IO Interests shall be designated as the Regular Interest regular interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest residual interest in REMIC VI. The Trust Administrator shall make an election to treat the segregated pool of assets consisting of the REMIC III Regular Interests and the REMIC VI Regular Interests as a REMIC for federal income tax purposes, and such segregated pool of assets will be designated as “REMIC VII.” For the purposes of the REMIC election in respect of REMIC VII, the REMIC VII Regular Interests shall be designated as the regular interests in REMIC VII and the Class R-VII Interest shall be designated as the residual Fremont 2006-B Pooling & Servicing Agreement 260 interest in REMIC VII. The Trust Administrator shall make an election to treat the segregated pool of assets consisting of the Class C Interest as a REMIC for federal income tax purposes, and such segregated pool of assets will be designated as “REMIC VIII.” For the purposes of the REMIC election in respect of REMIC VIII, the REMIC VIII Regular Interest shall be designated as the regular interest in REMIC VIII, and the Class RX-VIII Interest shall be designated as the residual interest in REMIC VIII. The Trust Administrator shall make an election to treat the segregated pool of assets consisting of the Class P Interest as a REMIC for federal income tax purposes, and such segregated pool of assets will be designated as “REMIC IX.” For the purposes of the REMIC election in respect of REMIC IX, the REMIC IX Regular Interest shall be designated as the regular interest in REMIC IX, and the Class RX-IX Interest shall be designated as the residual interest in REMIC IX. The Trust Administrator shall make an election to treat the segregated pool of assets consisting of the Class SWAP-I-IO Interest as a REMIC for federal income tax purposes, and such segregated pool of assets shall be designated as “REMIC X.” For the purposes of the REMIC election in respect of REMIC X, the REMIC X Regular Interest shall be designated as the regular interest in REMIC X, and the Class RX-X Interest shall be designated as the residual interest in REMIC X. The Trust Administrator shall make an election to treat the segregated pool of assets consisting of the Class SL-C Interest as a REMIC for federal income tax purposes, and such segregated pool of assets will be designated as “REMIC XI.” For the purposes of the REMIC election in respect of REMIC XI, the REMIC XI Regular Interest shall be designated as the regular interest in REMIC XI, and the Class RX-XI Interest shall be designated as the residual interest in REMIC XI. The Trust Administrator shall make an election to treat the segregated pool of assets consisting of the Class SWAP-II-IO Interest as a REMIC for federal income tax purposes, and such segregated pool of assets will be designated as “REMIC XII.” For the purposes of the REMIC election in respect of REMIC XII, the REMIC XII Regular Interest shall be designated as the regular interest in REMIC XII, and the Class RX-XII Interest shall be designated as the residual interest in REMIC XII. Neither the Trustee nor the Trust Administrator shall not permit the creation of any “interests” in any Trust REMIC created hereunder (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest and the interests represented by the Certificatesthose designated above.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Each such Such election will be made by the Trust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I-A, the REMIC I I-A Regular Interests shall be designated as the Regular Interests in REMIC I I-A and the Class R-I IA Residual Interest shall be designated as the Residual Interest Interests in REMIC I. The I-A. For the purposes of the REMIC II election in respect of REMIC I-B, the REMIC I-B Regular Interests shall be designated as the Regular Interests in REMIC II I-B and the Class R-II IB Residual Interest shall be designated as the Residual Interests in REMIC I-B. For the purposes of the REMIC election in respect of REMIC I-C, the Group 1 Certificates (other than the Class 1-R Certificates) shall be designated as the Regular Interests in REMIC I-C and the Class R-IC Residual Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, I-C. Neither the Mezzanine Certificates, Trustee nor the Swap-IO Interest, the Class CE Interest and the Class P Interest Trust Administrator shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “interests” in any Trust REMIC I-A, REMIC I-B or REMIC I-C (within the meaning of Section 860G of the Code) other than the REMIC I I-A Regular Interests, REMIC I-B Regular Interests and the Group 1 Certificates. For the purposes of the REMIC II Regular Interestselection in respect of REMIC II-A, the REMIC II-A Regular Interests shall be designated as the Regular Interests in REMIC II-A and the Class CE InterestR-IIA Residual Interest shall be designated as the Residual Interests in REMIC II-A. For the purposes of the REMIC election in respect of REMIC II-B, the Group 2 Certificates (other than the Class P Interest, 2-R Certificates) shall be designated as the SwapRegular Interests in REMIC II-IO Interest B and the interests represented Class R-IIB Residual Interest shall be designated as the Residual Interest in REMIC II-B. Neither the Trustee nor the Trust Administrator shall permit the creation of any “interests” in REMIC II-A or REMIC II-B (within the meaning of Section 860G of the Code) other than the REMIC II-A Regular Interests and the Group 2 Certificates. The Trustee shall elect to treat each REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Such election will be made by the CertificatesTrust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued.

REMIC Administration. (a) The An election will be made by the Certificate Administrator on behalf of the Trustee shall elect to treat each Trust REMIC the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Collection Account, the Reserve Accounts and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and, to the extent of the Trust’s interest therein, any related REO Properties as a REMIC under the Code and(such REMIC being herein designated as “REMIC I”), if necessary, under applicable state lawother than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Loan. Each such election Such elections will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC I I, and the REMIC I Residual Interest (which shall be evidenced by the Class R-I Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC I. The An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC II”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC II II, and the REMIC II Residual Interest (which shall be evidenced by the Class R-II Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC II. The An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC III”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Interests are issued. For purposes of such election, the Class A A-0, Xxxxx X-0, Class A-AB, Class A-0, Xxxxx X-0, Class D, Class E, Class F, Class G and Class H Certificates, the Mezzanine CertificatesEC Trust REMIC III Regular Interests, the Swap-IO InterestSwap REMIC III Regular Interests, the Class CE J REMIC III Regular Interest and the Class P Interest X REMIC III Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC III III, and the REMIC III Residual Interest (which shall be evidenced by the Class R-III Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee Certificate Administrator shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest Interests and the interests represented by the CertificatesREMIC III Interests.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Trustee on behalf of the Trust to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Collection Account and the Distribution Account, the Insurance Policies and any REO Properties and any other assets constituting REMIC I (as set forth on the definition of REMIC I) as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I 156 Regular Interests shall each be designated as the Regular Interests a separate class of "regular interests" in REMIC I and the Class R-I Interest Certificates shall be designated as the Residual Interest sole class of "residual interests" in REMIC I. The An election will be made by the Trustee on behalf of REMIC II to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole class of "residual interests" in REMIC II. The Class A Certificates, An election will be made by the Mezzanine Certificates, Trustee on behalf of REMIC III to treat the Swap-IO Interestsegregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class CE A1, Class A2, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K and Class L Certificates and each Component Interest and of the Class P Interest X Certificates shall be designated as the Regular Interests "regular interests" in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole class of "residual interests" in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VIIII. The Trustee shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Treasury regulation Section 860G 1.860D-1(b)(1)) in any of the Code) REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest Interests and the interests represented evidenced by the Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return (including Form 8811) or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued, copies of which forms and returns shall promptly be furnished by the Trustee to the NIMS Insurer and the Class I-A4 Insurer. For the purposes of the REMIC election in respect of REMIC I1, the REMIC I 1 Regular Interests shall be designated as the Regular Interests in REMIC I 1 and the Class R-I R-1 Interest shall be designated as the Residual Interest in REMIC I. The 1. For the purposes of the REMIC II election in respect of REMIC 2, the REMIC 2 Regular Interests shall be designated as the Regular Interests in REMIC II 2 and the Class R-II R-2 Interest shall be designated as the Residual Interest in REMIC II2. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest REMIC 3 Regular Interests shall be designated as the Regular Interests in REMIC III 3 and the Class R-III R-3 Interest shall be designated as the Residual Interest in REMIC III3. The CE For the purposes of the REMIC election in respect of REMIC 4, (i) the Regular Certificates (other than the Class C Certificates, the Class Swap IO Certificates and the Class P Certificates) and the REMIC 4 Regular Interests shall be designated as the Regular Interests in REMIC 4 and (ii) the Class R-4 Interest shall be designated as the Residual Interest in REMIC 4. For the purposes of the REMIC election in respect of REMIC CX, the Class C Certificates shall be designated as the Regular Interests in REMIC IV CX and the Class R-IV CX Interest shall be designated as the Residual Interest in REMIC IVCX. The For the purposes of the REMIC election in respect of REMIC PX, the Class P Certificates shall be designated as the Regular Interests in REMIC V PX and the Class R-V PX Interest shall be designated as the Residual Interest in REMIC V. PX. For the purposes of the REMIC VI Regular election in respect of REMIC SwapX, the Class Swap IO Upper-Tier Interest SWAP-IO shall be designated as the Regular Interest Interests in REMIC VI SwapX and the Class R-VI SwapX Interest shall be designated as the Residual Interest in REMIC VI. SwapX. The Trustee shall not permit the creation of any “interests” in any Trust REMIC 1, REMIC 2, REMIC 3, REMIC 4, REMIC CX, REMIC SwapX or REMIC PX (within the meaning of Section 860G of the Code) other than the REMIC I 1 Regular Interests, the REMIC II 2 Regular Interests, the Class CE InterestREMIC 3 Regular Interests, the Class P Interest, the Swap-IO Interest REMIC 4 Regular Interests and the interests represented by the Certificates.

REMIC Administration. (a) The Trustee Paying Agent shall elect make elections or cause elections to be made to treat each Trust of the Loan REMIC, the Lower-Tier REMIC and the Upper-Tier REMIC as a REMIC under the Code and, if necessary, under applicable state lawApplicable State and Local Tax Law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Uncertificated Lower-Tier Interests and the Certificates are issued. For the purposes of the REMIC election in respect of REMIC Ithe Upper-Tier REMIC, each Class of the Regular Certificates, the Class BM Certificates and the Class AC Certificates shall be designated as the "regular interests" (in the case of the Class NR Certificates, exclusive of the portion thereof, representing the right to Excess Interest and Amounts in the Excess Interest Distribution Account) and the Class R Certificates shall be designated as the sole class of "residual interests" in the Upper-Tier REMIC. For purposes of the REMIC I election in respect of the Lower-Tier REMIC, each Class of Uncertificated Lower-Tier Interests shall be designated as the "regular interests" and the Class LR Certificates shall be designated as the sole class of "residual interests" in the Lower-Tier REMIC. For purposes of the REMIC election in respect of the Loan REMIC, each Class of Loan REMIC Regular Interests shall be designated as the Regular Interests in REMIC I "regular interests" and the Loan REMIC Residual Interest, represented by the Class R-I Interest LR Certificates, shall be designated as the Residual Interest sole class of "residual interests" in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and Loan REMIC. None of the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A CertificatesSpecial Servicer, the Mezzanine CertificatesServicer, the Swap-IO Interest, Paying Agent nor the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in the Loan REMIC, the Lower-Tier REMIC or the Upper-Tier REMIC other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest and the interests represented by the Certificatesforegoing interests.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Each such Such election will be made by the Trust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I-A, the REMIC I I-A Regular Interests shall be designated as the Regular Interest in REMIC I-A and the Class R-IA Residual Interest shall be designated as the Residual Interests in REMIC I-A. For the purposes of the REMIC election in respect of REMIC I-B, the Group 1 Certificates (other than the Class I-R Certificates) shall be designated as the Regular Interests in REMIC I-B and the Class R-IB Residual Interest shall be designated as the Residual Interest in REMIC I-B. For the purposes of the REMIC election in respect of REMIC II-A, the REMIC II-A Regular Interests shall be designated as the Regular Interests in REMIC I II-A and the Class R-I Interest shall be designated as the IIA Residual Interest in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates-A. For the purposes of the REMIC election in respect of REMIC II-B, the Mezzanine Certificates, the Swap-IO Interest, Group 2 Certificates (other than the Class CE Interest and the Class P Interest 2-R Certificates) shall be designated as the Regular Interests in REMIC III II-B and the Class R-III IIB Residual Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates II-B. Neither the Trustee nor the Trust Administrator shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “interests” in any Trust REMIC I-B or REMIC II-B (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest Group 1 Certificates and the interests represented Group 2 Certificates. The Trustee shall elect to treat each REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Such election will be made by the CertificatesTrust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Accounts, the Interest Reserve Accounts, the Distribution Account and the Reserve Account, the Insurance Policies and any related amounts REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC I Interests are issued. For purposes of such election, the REMIC I Regular Interests shall each be designated as a separate class of "regular interests" in REMIC I and the Class [R-I] Certificates shall be designated as the sole class of "residual interests" in REMIC I. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests "regular interests" in REMIC II and the Class [R-II Interest II] Certificates shall be designated as the Residual Interest sole class of the "residual interests" in REMIC II. The Class A Certificates, An election will be made by the Mezzanine Certificates, Paying Agent to treat the Swap-IO Interestsegregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class CE Interest [A-1], Class [A-1A], Class [A-2], Class [A-3-1], Class [A-3-2], Class [A-AB], Class [A-4A], Class [A-4B], Class [A-1A], Class [A-J], Class [B], Class [C], Class [D], Class [E], Class [F], Class [G], Class [H], Class [J], Class [K], Class [L], Class [M], Class [N], Class [O], Class [P], Class [X-1], Class [X-2] and Class [X-Y] Certificates and the Class P Interest A-3-1FL Regular Interest, shall be designated as the Regular Interests "regular interests" in REMIC III and the Class [R-III Interest shall be designated as the Residual Interest in REMIC III. The CE ] Certificates shall be designated as the Regular Interests sole class of "residual interests" in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VIIII. The Trustee and the Paying Agent shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest REMIC III Regular Interests and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I-A, the REMIC I I-A Regular Interests shall be designated as the Regular Interests in REMIC I I-A and the Class R-I Certificates shall be designated as the Residual Interest in REMIC I-A. For the purposes of the REMIC election in respect of REMIC I-B, the REMIC I-B Regular Interests shall be designated as the Regular Interests in REMIC I-B and the Class R-II Certificates shall be designated as the Residual Interest in REMIC I-B. For the purposes of the REMIC election in respect of REMIC I-C, the REMIC I-C Regular Interests shall be designated as the Regular Interests in REMIC I-C and the Class R-III Certificates Interest shall be designated as the Residual Interest in REMIC I. The I-C. For the purposes of the REMIC election in respect of REMIC II, the REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Group I Class A Certificates, the Group II Class A Certificates, the Group III Class A Certificates, each of the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest Certificates and the Class P Interest Certificates (other than the right to receive amounts, if any, from the Net WAC Rate Carryover Reserve Accounts) shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “"interests” " in any Trust REMIC (within the meaning of Section 860G of the Code) other than the REMIC I I-A Regular Interests, the REMIC I-B Regular Interests, the REMIC I-C Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest Interests and the interests represented by the Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account, the Insurance Policies and any REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole Class of "residual interests" in REMIC IV I. The Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee Paying Agent shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests and the Residual Certificates. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class CE InterestR-II Certificates shall be designated as the sole Class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class P InterestA-1, Class A-2, Class X-1 (each Class X-1 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Swap-IO Interest Preliminary Statement), Class X-2 (each Class X-2 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M and Class N Certificates shall be designated as the "regular interests" in REMIC III and the interests represented by Class R-III Certificates shall be designated as the Certificatessole Class of " residual interests" in REMIC III.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Trustee Paying Agent to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Accounts, the Interest Reserve Account, the Distribution Account and the Reserve Account, the Insurance Policies and any related amounts REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing allocable to a Serviced Companion Loan. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate class of "regular interests" in REMIC I and the Class R-I Interest Certificates shall be designated as the Residual Interest sole class of "residual interests" in REMIC I. The An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole class of the "residual interests" in REMIC II. The Class A Certificates, An election will be made by the Mezzanine Certificates, Paying Agent to treat the Swap-IO Interestsegregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC Regular Certificates and the Floating Rate Regular Interests are issued. For purposes of such election, the Class CE Interest A-1, Class A-1A, Class A-2, Class A-3, Class A-4, Class A-M, Class A-MA, Class A-J, Class A-JA, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O, Class P, Class Q, Class S, Class X-1 and Class X-2 Certificates and the Class P Interest A-MFL and Class A-JFL Regular Interests shall be designated as the Regular Interests "regular interests" in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole class of "residual interests" in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VIIII. The Trustee and the Paying Agent shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE InterestREMIC Regular Certificates, the Class P Interest, the Swap-IO Interest Floating Rate Regular Interests and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Account, and the Interest Reserve Account, the Reserve Account and the Distribution Account (exclusive of the Class A-4FL Floating Rate Account, the Class A-MFL Floating Rate Account and the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Mortgage Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest Certificates shall be designated as the Residual Interest sole Class of "residual interests" in REMIC I. The An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests "regular interests" in REMIC II and the Class R-II Certificates shall be designated as the sole Class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates, the Class A-4FL Regular Interest and the Class A-MFL Regular Interest are issued. For purposes of such election, the Class A-1, Class A-1A, Class A-2, Class A-3-1, Class A-3-2, Class A-AB, Class A-4, Class A-M, Class A-J, Class X, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O, Class P, Class Q and Class S Certificates, the Class A-4FL Regular Interest and the Class A-MFL Regular Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests "regular interests" in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole Class of "residual interests" in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VIIII. The Trustee and the Paying Agent shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Certificates, the Class CE A-4FL Regular Interest, the Class P Interest, the SwapA-IO MFL Regular Interest and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee REMIC elections as set forth in the Preliminary Statement shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. The regular interests and residual interest in each REMIC shall be as designated in the Preliminary Statement. For the purposes of the REMIC election elections in respect of the Trust Fund, (i) the REMIC I1 Regular Interests will represent the “regular interests” in REMIC 1, the Class R-1 Interest will constitute the sole class of “residual interests” in REMIC I 1, (ii) the REMIC 2 Regular Interests shall be designated as will represent the Regular Interests “regular interests” in REMIC I and 2, the Class R-I R-2 Interest shall be designated as will constitute the Residual Interest sole class of “residual interests” in REMIC I. The REMIC II Regular Interests shall be designated as 2, (iii) the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine CertificatesClass M Certificates and the Class B Certificates (exclusive of any right to receive distributions from the Net WAC Rate Carryover Reserve Account in respect of the Net WAC Rate Carryover Amount or the Swap Account or any obligation to make payments to the Swap Account), the Swap-IO Class C Interest, the Class CE IO Interest and the Class P Interest shall be designated as the Regular Interests “regular interests” in REMIC III 3 and the Class R-3 Interest will constitute the sole class of “residual interests” in REMIC 3, (iv) the Class C Certificates (exclusive of any obligation to make payments to the Net WAC Rate Carryover Reserve Account in respect of the Net WAC Rate Carryover Amount) will represent ownership of “regular interests” in REMIC 4 and the Class R-4 Interest will constitute the sole class of “residual interests” in REMIC 4, (v) the Class P Certificates will represent ownership of “regular interests” in REMIC 5 and the Class R-5 Interest will constitute the sole class of “residual interests” in REMIC 5, (vi) the REMIC 6 Regular Interest SWAP IO will represent ownership of “regular interests” in REMIC 6 and the Class R-6 Interest will constitute the sole class of “residual interests” in REMIC 6, (vii) the Class R Certificates will evidence ownership of the Class R-1 Interest, Class R-2 Interest and Class R-3 Interest and (viii) the Class R-III X Certificates will evidence ownership of the Class R-4 Interest, the Class R-5 Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IVR-6 Interest. The P Certificates shall be designated as the Regular Interests in REMIC V Securities Administrator and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) in any REMIC created hereunder other than (a) the REMIC I 1 Regular Interests, the REMIC II 2 Regular Interests, the REMIC 3 Regular Interests, the REMIC 4 Regular Interests, the REMIC 5 Regular Interests or the REMIC 6 Regular Interests, the ownership of which is represented by the Class CE A Certificates, the Class M Certificates, the Class B Certificates, the REMIC 6 Regular Interest SWAP IO, the Class C Certificates and the Class P Certificates and (b) the Class R-1 Interest, the Class P R-2 Interest, the Swap-IO Class R-3 Interest, the Class R-4 Interest, the Class R-5 Interest and the interests represented by Class R-6 Interest. The Securities Administrator will apply for an Employee Identification Number from the Certificates.IRS via form SS-4 or any other acceptable method for each Trust REMIC

REMIC Administration. (a) The Trustee REMIC elections as set forth in the Preliminary Statement shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. The regular interests and residual interest in each REMIC shall be as designated in the Preliminary Statement. For the purposes of the REMIC election elections in respect of the Trust Fund, (i) the REMIC I1 Regular Interests will represent the “regular interests” in REMIC 1, the Class R-1 Interest will constitute the sole class of “residual interests” in REMIC I 1, (ii) the REMIC 2 Regular Interests shall be designated as will represent the Regular Interests “regular interests” in REMIC I 2, the Class R-2 Interest will constitute the sole class of “residual interests” in REMIC 2, (iii) the Class A Certificates and the Class R-I Interest shall be designated as M Certificates (exclusive of any right to receive distributions from or obligations to make payments to the Residual Interest Net WAC Rate Carryover Reserve Account in REMIC I. The REMIC II Regular Interests shall be designated as respect of the Regular Interests in REMIC II and Net WAC Rate Carryover Amount or the Swap Account), the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO C Interest, the Class CE IO Interest and the Class P Interest shall be designated as the Regular Interests “regular interests” in REMIC III 3 and the Class R-3 Interest will constitute the sole class of “residual interests” in REMIC 3, (iv) the Class C Certificates (exclusive of any right to receive distributions from or obligation to make payments to the Net WAC Rate Carryover Reserve Account in respect of the Net WAC Rate Carryover Amount or the Swap Account) will represent ownership of “regular interests” in REMIC 4 and the Class R-4 Interest will constitute the sole class of “residual interests” in REMIC 4, (v) the Class P Certificates will represent ownership of “regular interests” in REMIC 5 and the Class R-5 Interest will constitute the sole class of “residual interests” in REMIC 5, (vi) the REMIC 6 Regular Interest SWAP IO will represent ownership of “regular interests” in REMIC 6 and the Class R-6 Interest will constitute the sole class of “residual interests” in REMIC 6, (vii) the Class R Certificates will evidence ownership of the Class R-1 Interest, Class R-2 Interest and Class R-3 Interest and (viii) the Class R-III X Certificates will evidence ownership of the Class R-4 Interest, the Class R-5 Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IVR-6 Interest. The P Certificates shall be designated as the Regular Interests in REMIC V Securities Administrator and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) in any REMIC created hereunder other than (a) the REMIC I 1 Regular Interests, the REMIC II 2 Regular Interests, the REMIC 3 Regular Interests, the REMIC 4 Regular Interests, the REMIC 5 Regular Interests or the REMIC 6 Regular Interests, the ownership of which is represented by the Class CE A and Class M Certificates, the SWAP IO, the Class C Certificates and the Class P Certificates and (b) the Class R-1 Interest, the Class P R-2 Interest, the Swap-IO Class R-3 Interest, the Class R-4 Interest, the Class R-5 Interest and the interests represented by Class R-6 Interest. The Securities Administrator will apply for an Employee Identification Number from the Certificates.IRS via form SS-4 or any other acceptable method for each Trust REMIC

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest, Exit Fees, Extension Fees or Extension Term Prepayment Premiums payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Account, the Interest Reserve Account, the Reserve Account and the Distribution Account (exclusive of the Class P Sub-account), the Insurance Policies and any related amounts in the REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Mortgage Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest Certificates shall be designated as the Residual Interest sole Class of "residual interests" in REMIC I. The An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole Class of the "residual interests" in REMIC II. The Class A Certificates, An election will be made by the Mezzanine Certificates, Paying Agent to treat the Swap-IO Interestsegregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class CE Interest A-1, Class A-1A, Class A-2, Class A-3, Class A-M, Class A-J, Class X, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O and Class P Certificates (but other than the Class P Interest Grantor Trust Interest) shall be designated as the Regular Interests "regular interests" in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole Class of "residual interests" in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VIIII. The Trustee and the Paying Agent shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest REMIC III Regular Interests and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee Securities Administrator shall elect make an election to treat each the Trust REMIC Fund as a REMIC five REMICs under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return (including Form 8811) or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election elections in respect of the Trust Fund, (i) the REMIC I1 Regular Interests will represent the “regular interests” in REMIC 1, the Class R-1 Interest will constitute the sole class of “residual interests” in REMIC I 1, (ii) REMIC 2 Regular Interests shall be designated as will represent the Regular Interests “regular interests” in REMIC I 2, the Class R-2 Interest will constitute the sole class of “residual interests” in REMIC 2, (iii) the Class A Certificates, Class M Certificates and Class X Certificates (exclusive of the right to receive payments from the Corridor Contract Reserve Fund) and the Class C Interest and Class P Interest will represent the “regular interests” in REMIC 3, the Class R-3 Interest will constitute the sole Class of “residual interests” in REMIC 3, (iv) the Class C Certificates will represent the “regular interests” in REMIC 4, the Class R-4 Interest will constitute the sole Class of “residual interests” in REMIC 4, (v) the Class P Certificates will represent the “regular interests” in REMIC 5, the Class R-5 Interest will constitute the sole Class of “residual interests” in REMIC 5 and (vi) the Class R Certificates will evidence ownership of the Class R-1 Interest, Class R-2 Interest and the Class R-3 Interest and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and X Certificates will evidence ownership of the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE R-4 Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC IIIR-5 Interest. The CE Certificates shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee Securities Administrator shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) in any REMIC created hereunder other than the REMIC I 1 Regular Interests, the REMIC II 2 Regular Interests, the Class CE C Interest, the Class P Interest, the Swap-IO Interest and the interests represented by Certificates. The Securities Administrator will apply for an Employee Identification Number from the CertificatesIRS via form SS-4 or any other acceptable method for each Trust REMIC.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Each such Such election will be made by the Trust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I-A, the REMIC I I-A Regular Interests shall be designated as the Regular Interests in REMIC I I-A and the Class R-I IA Residual Interest shall be designated as the Residual Interest Interests in REMIC I. The I-A. For the purposes of the REMIC II election in respect of REMIC I-B, the REMIC I-B Regular Interests shall be designated as the Regular Interests in REMIC II I-B and the Class R-II IB Residual Interest shall be designated as the Residual Interest Interests in REMIC II. The Class A CertificatesI-B. For the purposes of the REMIC election in respect of REMIC I-B, the Mezzanine Certificates, the Swap-IO Interest, Group 1 Certificates (other than the Class CE Interest and the Class P Interest 1-R Certificates) shall be designated as the Regular Interests in REMIC III and I-B. Neither the Class R-III Interest Trustee nor the Trust Administrator shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “interests” in any Trust REMIC I-A or REMIC I-B (within the meaning of Section 860G of the Code) other than the REMIC I I-A Regular Interests, REMIC I-B Regular Interests and the Group 1 Certificates. For the purposes of the REMIC II election in respect of REMIC II-A, the REMIC II-A Regular Interests shall be designated as the Regular Interests in REMIC II-A and the Class R-IIA Residual Interest shall be designated as the Residual Interests in REMIC II-A. For the purposes of the REMIC election in respect of REMIC II-B, the REMIC II-B Regular Interests shall be designated as the Regular Interests in REMIC II-B and the Class R-IIB Residual Interest shall be designated as the Residual Interests in REMIC II-B. For the purposes of the REMIC election in respect of REMIC II-B, the Group 2 Certificates (other than the Class 2-R Certificates) shall be designated as the Regular Interests in REMIC II-B and the Class R-IIC Residual Interest shall be designated as the Residual Interest in REMIC II-B. Neither the Trustee nor the Trust Administrator shall permit the creation of any “interests” in REMIC II-A, REMIC II-B or REMIC II-B (within the meaning of Section 860G of the Code) other than the REMIC II-A Regular Interests, the Class CE Interest, the Class P Interest, the SwapREMIC II-IO Interest B Regular Interests and the interests represented Group 2 Certificates. The Trustee shall elect to treat each REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Such election will be made by the CertificatesTrust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Accounts, the Interest Reserve Accounts, the Distribution Account and the Reserve Account, the Insurance Policies and any related amounts REO Account and any related REO Properties as a REMIC (“REMIC I”) under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC I Interests are issued. For purposes of such election, the REMIC I Regular Interests shall each be designated as a separate class of “regular interests” in REMIC I and the Class [R-I] Certificates shall be designated as the sole class of “residual interests” in REMIC I. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC (“REMIC II”) under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC II and the Class [R-II Interest II] Certificates shall be designated as the Residual Interest sole class of the “residual interests” in REMIC II. The Class A Certificates, An election will be made by the Mezzanine Certificates, Paying Agent to treat the Swap-IO Interestsegregated pool of assets consisting of the REMIC II Regular Interests as a REMIC (“REMIC III”) under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class CE Interest [A-1], Class [A-1A], Class [A-2], Class [A-3-1], Class [A-3-2], Class [A-AB], Class [A-4A], Class [A-4B], Class [A-1A], Class [A-J], Class [B], Class [C], Class [D], Class [E], Class [F], Class [G], Class [H], Class [J], Class [K], Class [L], Class [M], Class [N], Class [O], Class [P], Class [X-1], Class [X-2] and Class [X-Y] Certificates and the Class P Interest A-3-1FL Regular Interest, shall be designated as the Regular Interests “regular interests” in REMIC III and the Class [R-III Interest shall be designated as the Residual Interest in REMIC III. The CE ] Certificates shall be designated as the Regular Interests sole class of “residual interests” in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VIIII. The Trustee and the Paying Agent shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest REMIC III Regular Interests and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account, the Insurance Policies and any REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or the Federal Center Plaza Companion Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole Class of "residual interests" in REMIC IV I. The Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee Paying Agent shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests and the Residual Certificates. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class CE InterestR-II Certificates shall be designated as the sole Class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class P InterestA-1, Class A-2, Class X-1 (each Class X-1 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Swap-IO Interest Preliminary Statement), Class X-2 (each Class X-2 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N and Class O Certificates shall be designated as the "regular interests" in REMIC III and the interests represented by Class R-III Certificates shall be designated as the Certificatessole Class of "residual interests" in REMIC III.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Xxxxxxx Xxxx Loan, such amounts related to the Xxxxxxx Xxxx Loan as shall from time to time be held in the Certificate Account, the Interest Reserve Account and the Distribution Account, the related Insurance Policies and any related REO Properties as a REMIC ("Xxxxxxx Xxxx Loan REMIC ") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates Xxxxxxx Xxxx Loan REMIC Interests are issued. For purposes of such election, the Xxxxxxx Xxxx Loan REMIC Regular Interests shall each be designated as a Class of "regular interests" in the Xxxxxxx Xxxx Loan REMIC and the Xxxxxxx Xxxx Loan REMIC Residual Interest shall be designated as the sole Class of "residual interests" in the Xxxxxxx Xxxx Loan REMIC. An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Majority Mortgage Loans, the Xxxxxxx Xxxx Loan REMIC Regular Interest, such amounts related to the Majority Mortgage Loans as shall from time to time be held in the Certificate Account and the Interest Reserve Account, such amounts related to the Majority Mortgage Loans and the Xxxxxxx Xxxx Loan REMIC Regular Interest as shall from time to time be held in the Distribution Account (exclusive of the Excess Interest Sub-account and the Xxxxxxx Xxxx Sub-account), the related Insurance Policies and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or the WestShore Plaza Companion Loan. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC I Interests are issued. For purposes of such election, the REMIC I Regular Interests shall each be designated as a separate Class of "regular interests" in REMIC I and the REMIC I Residual Interest shall be designated as the sole Class of "residual interests" in REMIC I. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole Class of the "residual interests" in REMIC II. The Class A Certificates, An election will be made by the Mezzanine Certificates, Paying Agent to treat the Swap-IO Interestsegregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class CE Interest A-1, Class A-2, Class A-3, Class A-4, Class X-1 (each Class X-1 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class X-2 (each Class X-2 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N and Class O Certificates (but other than the Class P Interest A-1, Class X-1, Class X-2 and Class O Grantor Trust Interest) shall be designated as the Regular Interests "regular interests" in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole Class of "residual interests" in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VIIII. The Trustee and the Paying Agent shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMICs other than the Xxxxxxx Xxxx Loan REMIC Regular Interest, REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest REMIC III Regular Interests and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee Trust Administrator shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return (including Form 8811) or any appropriate state return for the taxable year ending on the last day of the calendar year in which 178 the Certificates are issued, copies of which forms and returns shall promptly be furnished by the Trust Administrator to the NIMS Insurer. For the purposes of the REMIC election in respect of REMIC I1A, the REMIC I 1A Regular Interests shall be designated as the Regular Interests in REMIC I 1A and the Class R-I R-1A Interest shall be designated as the Residual Interest in REMIC I. The 1A. For the purposes of the REMIC II election in respect of REMIC 1B, the REMIC 1B Regular Interests shall be designated as the Regular Interests in REMIC II 1B, and the Class R-II R-1B Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates1B. For the purposes of the REMIC election in respect of REMIC 2, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest REMIC 2 Regular Interests shall be designated as the Regular Interests in REMIC III 2 and the Class R-III R-2 Interest shall be designated as the Residual Interest in REMIC III2. The CE For the purposes of the REMIC election in respect of REMIC 3, (i) the Regular Certificates (other than the Class C Certificates and the Class P Certificates) and the REMIC 3 Regular Interests shall be designated as the Regular Interests in REMIC IV 3 and (ii) the Class R-IV R-3 Interest shall be designated as the Residual Interest in REMIC IV3. The For the purposes of the REMIC election in respect of REMIC X, the Class C Certificates and the Class P Certificates shall be designated as the Regular Interests in REMIC V X and the Class R-V X Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO X. Neither the Trustee nor the Trust Administrator shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “"interests” " in any Trust REMIC 1A, REMIC 1B, REMIC 2, REMIC 3 or REMIC X (within the meaning of Section 860G of the Code) other than the REMIC I 1A Regular Interests, the REMIC II 1B Regular Interests, the Class CE InterestREMIC 2 Regular Interests, the Class P Interest, the Swap-IO Interest REMIC 3 Regular Interests and the interests represented by the Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Account, the Interest Reserve Account, the Reserve Account and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Mortgage Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest Certificates shall be designated as the Residual Interest sole Class of "residual interests" in REMIC I. The An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole Class of the "residual interests" in REMIC II. The Class A Certificates, An election will be made by the Mezzanine Certificates, Paying Agent to treat the Swap-IO Interestsegregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class CE Interest A-1, Class X-0, Xxxxx X-0, Class A-AB, Class X-0X, Xxxxx X-0X, Xxxxx X-X, Class X, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O, Class P, Class LF and Class Q Certificates (but other than the Class P Interest Q Grantor Trust Interest) shall be designated as the Regular Interests "regular interests" in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole Class of "residual interests" in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VIIII. The Trustee and the Paying Agent shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest REMIC III Regular Interests and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account, the Insurance Policies and any REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole Class of "residual interests" in REMIC IV I. The Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee Paying Agent shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC Regular Certificates and the Residual Certificates. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class CE InterestR-II Certificates shall be designated as the sole Class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class P InterestA-1, Class A-2, Class A-3, Class A-4, Class X-1 (each Class X-1 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Swap-IO Interest Preliminary Statement), Class X-2 (each Class X-2 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M and Class N Certificates shall be designated as the "regular interests" in REMIC III and the interests represented by Class R-III Certificates shall be designated as the Certificatessole Class of "residual interests" in REMIC III.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Trustee to treat the segregated pool of assets consisting of the Majority Mortgage Loans, the International Plaza Pari Passu Loan REMIC Regular Interest, such amounts related to the Majority Mortgage Loans as shall from time to time be held in the Certificate Account and the Interest Reserve Account, such amounts related to the Majority Mortgage Loans and the International Plaza Pari Passu Loan REMIC Regular Interest as shall from time to time be held in the Distribution Account, the related Insurance Policies and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Mortgage Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-REMIC I Residual Interest shall be designated as the Residual Interest sole Class of "residual interests" in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests and the Residual Certificates. An election will be made by the Trustee to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class CE InterestR-II Certificates shall be designated as the sole Class of the "residual interests" in REMIC II. An election will be made by the Trustee to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class P A-1, Class A-2, Class A-3, Class A-4, Class X-1 (each Class X-1 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class X-2 (each Class X-2 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O, Class P, Class Q and Class S Certificates (but other than the Class S Grantor Trust Interest) shall be designated as the "regular interests" in REMIC III and the Class R-III Certificates shall be designated as the sole Class of "residual interests" in REMIC III. The Trustee shall not permit the creation of any "interests" (within the meaning of Section 860G of the Code) in any of the REMICs other than the International Plaza Pari Passu Loan REMIC Regular Interest, REMIC I Regular Interests, the Swap-IO Interest REMIC II Regular Interests, the REMIC III Regular Interests and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account, the Insurance Policies and any REO Properties as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as a separate class of "regular interests" in the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole class of "residual interests" in the REMIC IV I. The Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee Paying Agent shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I, REMIC II, REMIC III and REMIC IV Regular Interests and the Residual Certificates. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular InterestsInterests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interest is issued. For the purposes of such election, the REMIC II Regular InterestsInterests shall be designated as the "regular interests" in REMIC II and the Class R-II Certificates shall be designated as the sole class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interest is issued. For the purposes of such election, the REMIC III Regular Interests shall be designated as the "regular interests" in REMIC III and the Class R-III Certificates shall be designated as the sole class of the "residual interests" in REMIC III. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC III Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC IV Certificates are issued. For purposes of such election, the Class CE InterestX-0, Xxxxx X-0, Class X, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L and Class M Certificates shall be designated as the "regular interests" in REMIC IV and the Class P Interest, R-IV Certificates shall be designated as the Swap-IO Interest and the interests represented by the Certificatessole class of "residual interests" in REMIC IV.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Each such Such election will be made by the Trust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I-A, the REMIC I I-A Regular Interests shall be designated as the Regular Interests in REMIC I I-A and the Class R-I IA Residual Interest shall be designated as the Residual Interest Interests in REMIC I. The I-A. For the purposes of the REMIC II election in respect of REMIC I-B, the REMIC I-B Regular Interests shall be designated as the Regular Interests in REMIC II I-B and the Class R-II IIB Residual Interest shall be designated as the Residual Interests in REMIC I-B. For the purposes of the REMIC election in respect of REMIC I-C, the Group 1 Certificates (other than the Class 1-R Certificates) shall be designated as the Regular Interests in REMIC I-C and the Class R-IC Residual Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, I-C. Neither the Mezzanine Certificates, Trustee nor the Swap-IO Interest, the Class CE Interest and the Class P Interest Trust Administrator shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “interests” in any Trust REMIC I-A, REMIC I-B or REMIC I-C (within the meaning of Section 860G of the Code) other than the REMIC I I-A Regular Interests, REMIC I-B Regular Interests and the Group 1 Certificates. For the purposes of the REMIC II Regular Interestselection in respect of REMIC II, the Class CE Interest, Group 2 Certificates (other than the Class P Interest2-R Certificates) shall be designated as the Regular Interests in REMIC II. Neither the Trustee nor the Trust Administrator shall permit the creation of any “interests” other than the Group 2 Certificates. The Trustee shall elect to treat each REMIC created hereunder as a REMIC under the Code and, the Swap-IO Interest and the interests represented if necessary, under applicable state law. Such election will be made by the CertificatesTrust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Account, the Interest Reserve Account, the Reserve Account and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Mortgage Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest Certificates shall be designated as the Residual Interest sole Class of "residual interests" in REMIC I. The An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole Class of the "residual interests" in REMIC II. The Class A Certificates, An election will be made by the Mezzanine Certificates, Paying Agent to treat the Swap-IO Interestsegregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class CE Interest A-1, Class A-2, Class A-3, Class A-AB, Class A-4, Class A-M, Class A-J, Class X-1, Xxxxx X-0, Xxass B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O and Class P Certificates (but other than the Class P Interest Grantor Trust Interest) shall be designated as the Regular Interests "regular interests" in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole Class of "residual interests" in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VIIII. The Trustee and the Paying Agent shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest REMIC III Regular Interests and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account, the Insurance Policies and any REO Properties as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the Corresponding REMIC I Regular Interests shall each be designated as a separate class of "regular interests" in the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole class of "residual interests" in the REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. I. The Trustee shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I, REMIC II and REMIC III Regular Interests and the Residual Certificates. An election will be made by the Trustee to treat the segregated pool of assets consisting of the REMIC I Regular InterestsInterests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interest is issued. For the purposes of such election, the REMIC II Regular InterestsInterests shall be designated as the "regular interests" in REMIC II and the Class R-II Certificates shall be designated as the sole class of the "residual interests" in REMIC II. An election will be made by the Trustee to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class CE InterestA-1, Class A-2, Class X-1, Class X-2, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J and Class K Certificates shall be designated as the "regular interests" in REMIC III and the Class P Interest, R-III Certificates shall be designated as the Swap-IO Interest and the interests represented by the Certificatessole class of "residual interests" in REMIC III.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Kimball Lane Loan, such amounts related to the Kimball Lane Loan as xxxxx xxxx time to time be held in the Certifixxxx Xxxxxxx, the Interest Reserve Account and the Distribution Account, the related Insurance Policies and any related REO Properties as a REMIC ("Kimball Lane Loan REMIC ") under the Code. Such election will be maxx xx Xxxx 0066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Kimball Lane Loan REMIC Interests are issued. For purposes of such xxxxxxxx, xxe Kimball Lane Loan REMIC Regular Interests shall each be designated xx x Xxxxx xf "regular interests" in the Kimball Lane Loan REMIC and the Kimball Lane Loan REMIC Residual Inxxxxxx xxxxx be designated as thx xxxx Xxxxx of "residual interests" in the Kimball Lane Loan REMIC. An election will be madx xx xxx Xxxing Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Majority Mortgage Loans, the Kimball Lane Loan REMIC Regular Interest, such amounts related to txx Xxxxxxxx Mortgage Loans as shall from time to time be held in the Certificate Account and the Interest Reserve Account, such amounts related to the Majority Mortgage Loans and the Kimball Lane Loan REMIC Regular Interest as shall from time to time xx xxxx xx the Distribution Account (exclusive of the Excess Interest Sub- account and the Kimball Lane Sub-account), the related Insurance Policies and any rxxxxxx XXX Xroperties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or the WestShore Plaza Companion Loan. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For purposes of such election, the REMIC I Regular Interests shall each be designated as a separate Class of "regular interests" in REMIC I and the REMIC I Residual Interest shall be designated as the sole Class of "residual interests" in REMIC I. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole Class of the "residual interests" in REMIC II. The Class A Certificates, An election will be made by the Mezzanine Certificates, Paying Agent to treat the Swap-IO Interestsegregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class CE Interest A-1, Class A-2, Class A-3, Class A-4, Class X-1 (each Class X-1 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class X-2 (each Class X-2 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N and Class O Certificates (but other than the Class P Interest A-1, Class X-1, Class X-2 and Class O Grantor Trust Interest) shall be designated as the Regular Interests "regular interests" in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole Class of "residual interests" in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VIIII. The Trustee and the Paying Agent shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMICs other than the Kimball Lane Loan REMIC Regular Interest, REMIC I Regular Interests, the REMIC xxx XXXXX II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest REMIC III Regular Interests and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee Depositor intends that each of the Lower-Tier REMIC and the Upper-Tier REMIC shall elect constitute, and that the affairs of each of the Lower-Tier REMIC and the Upper-Tier REMIC shall be conducted so as to qualify it as, a REMIC, and the provisions hereof shall be interpreted consistently with this intention. (b) The Certificate Administrator shall make or cause to be made an election on behalf of each of the Lower-Tier REMIC and the Upper-Tier REMIC to treat each Trust the segregated pool of assets constituting such REMIC as a REMIC under the Code and, if necessary, under applicable state lawCode. Each such election will shall be made by the Trustee on IRS Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates Trust Interests are issued. For the purposes of the REMIC election in respect of REMIC I, the REMIC I Regular Interests shall be . (c) The Closing Date is hereby designated as the Regular Interests in “Startup Day” of each of the Lower-Tier REMIC I and the Class RUpper-I Interest shall be designated as the Residual Interest in Tier REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G 860G(a)(9) of the Code. The “latest possible maturity date” of each Class of the Non-Retained Regular Certificates and each Uncertificated Lower-Tier Interest (other than the Class LVRR Uncertificated Interest and the LUVRR Uncertificated Interests) is the Rated Final Distribution Date for the purposes of Section 860G(a)(1) of the Code. The “latest possible maturity date” of the LUVRR Uncertificated Interests and the Class LVRR Uncertificated Interest is the Distribution Date in August 2041 for the purposes of Section 860G(a)(1) of the Code. (d) The Certificate Administrator shall prepare or cause to be prepared and file or cause to be filed with the IRS, on behalf of each of the Lower-Tier REMIC and the Upper-Tier REMIC, an application for a taxpayer identification number for such REMIC on IRS Form SS-4 or obtain such number by other permissible means. Within thirty days of the Closing Date, the Certificate Administrator shall furnish or cause to be furnished to the IRS, on IRS Form 8811 or as otherwise may be required by the Code, the name, title and address of the Persons that Trust Interest Owners may contact for tax information relating thereto (and the Certificate Administrator shall act as the representative of each of the Lower-Tier REMIC and the Upper-Tier REMIC for this purpose), together with such additional information as may be required by such Form, and shall update such information at the time or times and in the manner required by the Code (and the Depositor agrees within ten Business Days of the Closing Date to provide any information reasonably requested by the Servicer or the Certificate Administrator and necessary to make such filing). (e) The Certificate Administrator shall pay without any right of reimbursement the ordinary and usual expenses in connection with the preparation, filing and mailing of tax information reports and returns that are incurred by it in the ordinary course of its business, but extraordinary or unusual expenses, costs or liabilities incurred in connection with its tax related duties under this Agreement, including without limitation any expenses, costs or liabilities associated with audits or any administrative or judicial proceedings with respect to the Lower-Tier REMIC or the Upper-Tier REMIC that involve the IRS or state tax authorities, shall be reimbursable from the Trust. (f) The Certificate Administrator shall prepare or cause to be prepared, timely furnish or cause to be furnished to the Trustee to sign (and the Trustee shall timely sign), and the Certificate Administrator shall file or cause to be filed all federal, state and local income or franchise or other tax and information returns for each of the Lower-Tier REMIC and the Upper-Tier REMIC as the direct representative for such REMIC. Except as provided in Section 12.1(e), the expenses of preparing and filing such returns shall be borne by the Certificate Administrator. The Depositor shall provide on a timely basis to the Certificate Administrator or its designee such information with respect to each of the Lower-Tier REMIC and the Upper-Tier REMIC as is in its possession, and is reasonably requested by the Certificate Administrator to enable it to perform its obligations under this subsection, and the Certificate Administrator shall be entitled to rely on such information in the performance of its obligations hereunder. (g) The Certificate Administrator shall perform on behalf of each of the Lower-Tier REMIC and the Upper-Tier REMIC all reporting and other tax compliance duties that are the responsibility of such REMIC under the Code, the REMIC Provisions, or other compliance guidance issued by the IRS or any state or local taxing authority. Among its other duties, the Certificate Administrator shall provide (i) to the IRS or other Persons (including, but not limited to, the transferor of a Class R Certificate to a Disqualified Organization or to an agent that has acquired a Class R Certificate on behalf of a Disqualified Organization) such information as is necessary for the application of any tax relating to the transfer of a Class R Certificate to any Disqualified Organization and (ii) to the Trust Interest Owners such information or reports as are required by the Code or REMIC Provisions. The Depositor shall provide on a timely basis (and in no event later than 30 days after the Certificate Administrator’s request) to the Certificate Administrator or its designee such information with respect to each of the Lower-Tier REMIC and the Upper-Tier REMIC as is in its possession and is reasonably requested in writing by the Certificate Administrator to enable it to perform its obligations under this subsection. (h) The Class R Certificateholders, by acceptance of the Class R Certificates, agree, on behalf of themselves and all successor holders of such Class R Certificates, to the irrevocable designation of the Certificate Administrator as the “partnership representative” of each Trust REMIC within the meaning of Section 6223 of the Code (to the extent such provision is applicable to the Trust REMICs). The Certificate Administrator shall make any elections allowed under the Code (i) to avoid the application of Section 6221 of the Code (or successor provision) to any Trust REMIC and (ii) to avoid payment by any Trust REMIC under Section 6225 of the Code of any tax, penalty, interest or other amount imposed under the Code that would otherwise be imposed on any holder of any residual interest of any Trust REMIC, past or present. Each Holder of a Percentage Interest in the Class R Certificates, by acceptance thereof, is deemed to agree to any such elections. (i) The Trustee, the Certificate Administrator, the Holders of the Class R Certificates, the Servicer and the Special Servicer shall perform their obligations under this Agreement and the REMIC Provisions in a manner consistent with the status of each of the Lower-Tier REMIC and the Upper-Tier REMIC as a REMIC. (j) The Trustee, the Certificate Administrator, any Holder of the Class R Certificates, the Servicer and the Special Servicer shall not take any action or cause either the Lower-Tier REMIC or the Upper-Tier REMIC to take any action, within their respective control and the scope of their specific respective duties under this Agreement that, under the REMIC Provisions, could reasonably be expected to (i) endanger the status of either the Lower-Tier REMIC or the Upper-Tier REMIC as a REMIC or (ii) unless permitted under Section 12.2(a), result in the imposition of a tax upon either the Lower-Tier REMIC or the Upper-Tier REMIC (including but not limited to the tax on prohibited transactions as defined in Code Section 860F(a)(2) and the tax on prohibited contributions as defined in Code Section 860G(d)) (any such result in clause (i) or (ii), an “Adverse REMIC Event”) unless (A) the Trustee, the Certificate Administrator and the Servicer have received a Nondisqualification Opinion (at the expense of the party seeking to take such action or of the Trust if taken for the benefit of the Trust Interest Owners) with respect to such action or (B) the Trustee, the Certificate Administrator and the Servicer have received an opinion (at the expense of the party seeking to take such action or of the Trust if taken for the benefit of the Trust Interest Owners) to the effect that such action shall not cause either the Lower-Tier REMIC or the Upper-Tier REMIC to fail to qualify as a REMIC and that no tax shall actually be imposed. (k) Any and all federal, state and local taxes imposed on the Upper-Tier REMIC or the Lower-Tier REMIC or its assets or transactions, including, without limitation, “prohibited transaction” taxes as defined in Section 860F of the Code, and any tax on contributions imposed by Section 860G(d) of the Code, shall be paid from the Collection Account; provided that the Servicer, upon two (2) days prior written notice, shall remit from the Collection Account to the Certificate Administrator the amount of any such tax that the Certificate Administrator notifies the Servicer is due; provided, further, if such taxes shall have been imposed on account of the negligence, bad faith, fraud or willful misconduct of any party hereto, or in connection with the breach of any representation or warranty made by any party hereto in this Agreement, then such taxes shall be paid by such party. (l) The Certificate Administrator shall, for federal income tax purposes, maintain books and records with respect to the Lower-Tier REMIC and the Upper-Tier REMIC on a calendar year and on an accrual basis. Notwithstanding anything to the contrary contained herein or in the Mortgage Loan Documents (but subject to Section 1.3), all amounts collected on the Mortgage Loan shall, for federal income tax purposes, be allocated first to interest due and payable on the Mortgage Loan (including interest on overdue interest) other than Default Interest. The books and records shall be sufficient concerning the nature and amount of the investments of the Lower-Tier REMIC and the Upper-Tier REMIC to show that such REMIC has complied with the REMIC I Regular Provisions. (m) None of the Certificate Administrator, the Trustee, the Servicer or the Special Servicer shall enter into any arrangement by which either the Lower-Tier REMIC or the Upper-Tier REMIC shall receive a fee or other compensation for services. (n) In order to enable the Certificate Administrator to perform its duties as set forth herein, the Depositor shall provide, or cause to be provided, to the Certificate Administrator within ten days after the Closing Date, all information or data that the Certificate Administrator reasonably determines to be relevant for tax purposes on the valuations and offering prices of the Trust Interests, including, without limitation, the REMIC II Regular yield, issue prices, pricing prepayment assumption and projected cash flows of the Trust Interests, as applicable, and the Class CE Interestprojected cash flows on the Mortgage Loan. Thereafter, the Class P InterestDepositor, the Swap-IO Interest Trustee, the Servicer and the interests represented Special Servicer shall provide to the Certificate Administrator, promptly upon request therefor, any such additional information or data that the Certificate Administrator may, from time to time, reasonably request in order to enable the Certificate Administrator to perform its duties as set forth herein. The Certificate Administrator is hereby directed to use any and all such information or data provided by the CertificatesTrustee, the Depositor, the Servicer and the Special Servicer in the preparation of all federal, state or local income, franchise or other tax and information returns and reports for each of the Lower-Tier REMIC and the Upper-Tier REMIC to Trust Interest Owners as required herein. The Depositor hereby indemnifies the Certificate Administrator for any and all claims, losses, damages, penalties, fines, forfeitures, legal fees and expenses and related costs, judgments or other costs and expenses of the Certificate Administrator arising from any errors or miscalculations of the Certificate Administrator pursuant to this Section 12.1 that result from any failure of the Depositor to provide or to cause to be provided, accurate information or data to the Certificate Administrator (but not resulting from the methodology employed by the Certificate Administrator) on a timely basis and such indemnifications shall survive the termination of this Agreement and the termination of the Certificate Administrator. The Certificate Administrator agrees that all such information or data so obtained by it shall be regarded as confidential information and agrees that it shall use its best reasonable efforts to retain in confidence, and shall ensure that its officers, employees and representatives retain in confidence, and shall not disclose, without the prior written consent of the Depositor, any or all of such information or data, or make any use whatsoever (other than for the purposes contemplated by this Agreement) of any such information or data without the prior written consent of the Depositor, unless such information is generally available to the public (other than as a result of a breach of this Section) or is required by law or applicable regulations to be disclosed. (o) For the avoidance of doubt, the Lower-Tier Distribution Account, Collection Account and Foreclosed Property Account (including interest, if any, earned on the investment of funds in such accounts) will be owned by the Lower-Tier REMIC, and the Upper-Tier Distribution Account will be owned by the Upper-Tier REMIC, each for federal income tax purposes.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Account, the Class A-4FL Floating Rate Account, the Class A-MFL Floating Rate Account and the Interest Reserve Account, the Reserve Account and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Mortgage Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest Certificates shall be designated as the Residual Interest sole Class of "residual interests" in REMIC I. The An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests "regular interests" in REMIC II and the Class R-II Certificates shall be designated as the sole Class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates, the Class A-4FL Regular Interest and the Class A-MFL Regular Interest are issued. For purposes of such election, the Class A-1, Class A-1A, Class A-2, Class A-3, Class A-4, Class A-J, Class X-1, Class X-2, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O and Class P Certificates and the Class A-4FL Regular Interest and the Class A-MFL Regular Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests "regular interests" in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole Class of "residual interests" in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VIIII. The Trustee and the Paying Agent shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the cclxxxviii REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Certificates, the Class CE A-4FL Regular Interest, the Class P Interest, the SwapA-IO MFL Regular Interest and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will shall be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I, (i) the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The I, (ii) the REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, (iii) the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest REMIC III Regular Interests shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The , (iv) the Class A Certificates, the Mezzanine Certificates (exclusive of the right to receive payments from the Net WAC Carryover Reserve Account or the Swap Account or the obligation to make payments to the Swap Account), the Class SWAP-IO Interest, the Group II SWAP-IO Interest, the Class CE Certificates Interest and the Class P Interest shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P , (v) the Class CE Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO V, (vi) the Class P Certificates shall be designated as the Regular Interest Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI, (vii) REMIC VII Regular Interest SWAP-IO shall be designated as the Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII and (viii) REMIC VIII Regular Interest Group II SWAP-IO shall be designated as the Regular Interests in REMIC VIII and the Class R-VIII Interest shall be designated as the Residual Interest in REMIC VIII. The Trustee shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests, the Class CE Interest, the Class P Interest, the SwapClass SWAP-IO Interest, the Group II SWAP-IO Interest and the interests represented by the Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Accounts, the Interest Reserve Accounts, the Distribution Account and the Reserve Account, the Insurance Policies and any related amounts REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate class of "regular interests" in REMIC I and the Class R-I Interest Certificates shall be designated as the Residual Interest sole class of "residual interests" in REMIC I. The An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole class of the "residual interests" in REMIC II. The Class A Certificates, An election will be made by the Mezzanine Certificates, Paying Agent to treat the Swap-IO Interestsegregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class CE Interest A-1, Class A-2, Class A-3, Class A-4, Class A-AB, Class A-5, Class A-1A, Class A-J, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O, Class P, Class X-1, Class X-2 and the Class P Interest X-Y Certificates, shall be designated as the Regular Interests "regular interests" in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole class of "residual interests" in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VIIII. The Trustee and the Paying Agent shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest REMIC III Regular Certificates and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Account, the Interest Reserve Account, the Reserve Account and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Mortgage Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest Certificates shall be designated as the Residual Interest sole Class of "residual interests" in REMIC I. The An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole Class of the "residual interests" in REMIC II. The Class A Certificates, An election will be made by the Mezzanine Certificates, Paying Agent to treat the Swap-IO Interestsegregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class CE Interest A-1, Class X-0, Xxxxx X-0, Class A-AB, Class A-4, Class A-M, Class A-J, Class X, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O, Class MMA-NA, Class MMB-NA and Class P Certificates (but other than the Class P Interest Grantor Trust Interest) shall be designated as the Regular Interests "regular interests" in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole Class of "residual interests" in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VIIII. The Trustee and the Paying Agent shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest REMIC III Regular Interests and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Account, the Interest Reserve Account, the Reserve Account and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Mortgage Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest Certificates shall be designated as the Residual Interest sole Class of "residual interests" in REMIC I. The An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the Regular Interests "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole Class of the "residual interests" in REMIC II. The Class A Certificates, An election will be made by the Mezzanine Certificates, Paying Agent to treat the Swap-IO Interestsegregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class CE Interest A-1, Class X-0, Xxxxx X-0, Class A-AB, Class A-4, Class A-M, Class A-J, Class X, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O and Class P Certificates (but other than the Class P Interest Grantor Trust Interest) shall be designated as the Regular Interests "regular interests" in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole Class of "residual interests" in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VIIII. The Trustee and the Paying Agent shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest REMIC III Regular Interests and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee shall elect make an election to treat each the Trust REMIC Fund as a REMIC three separate REMICs under the Code andCode, and if necessary, under applicable state law. Each such Such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes The assets of the Lower-Tier REMIC election will consist of all of the assets constituting the Trust Fund other than the assets of the Middle-Tier REMIC and Upper-Tier REMIC and the Interest Cap Agreement described in respect this paragraph (a). The Lower-Tier REMIC will issue classes of REMIC I, interests which will be the REMIC I Lower-Tier Regular Interests shall (which will be designated as uncertificated and will represent the "regular interests" in the Lower-Tier REMIC) and the Class LR Certificates, which will be the sole class of "residual interests" in the Lower-Tier REMIC. The Trustee will hold the Lower-Tier Regular Interests in trust for the benefit of the Middle-Tier REMIC. The assets of the Middle-Tier REMIC I will consist of the Lower-Tier Regular Interests and the Middle-Tier Distribution Account. The Middle-Tier REMIC will issue classes of interests which will be the Middle-Tier Regular Interests (which will be uncertificated and will represent the "regular interests" in the Middle-Tier REMIC) and the Class RMR Certificates, which will be the sole class of "residual interests" in the Middle-I Interest shall be designated as Tier REMIC. The assets of the Residual Interest in Upper-Tier REMIC I. The REMIC II will consist of the Middle-Tier Regular Interests shall be designated as and the Regular Interests in Upper-Tier Distribution Account. The Upper-Tier REMIC II will issue the Class A Certificates and the Class RUT1, Class UT2, Class UT3 and Class UT4 Interests (which will represent the "regular interests" in the Upper-II Interest shall be designated as the Residual Interest in Tier REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, represented by the Class CE Interest X Certificates) and the Class P R Certificates, which will be the sole class of "residual interests" in the Upper-Tier REMIC. The Owner of the Class LR, Class MR or Class R Certificates, respectively, representing at any time the largest Percentage Interest in such Class shall be designated the "tax matters person" as defined in the Regular Interests in REMIC III Provisions (the "Tax Matters Person") with respect to the Lower-Tier REMIC, the Middle-Tier REMIC and the Upper-Tier REMIC, as applicable. Each holder of a Class RLR, Class MR and Class R Certificate, as a condition of ownership thereof, irrevocably appoints the Trustee to act as its agent and attorney-III Interest shall be designated as in-fact to perform all duties of the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VITax Matters Person. The Trustee shall not permit treat the creation Class A Certificateholders' rights to receive payments of any “interests” Basis Risk Shortfall pursuant to Section 6.05 (b)(viii) and (ix) as an interest rate cap agreement (the "Interest Cap Agreement") that the Trustee holds separate and apart from the portion of the Trust Fund treated as the Lower-Tier REMIC, the Middle-Tier REMIC and the Upper-Tier REMIC. The Trustee shall treat (i) the Class A Certificateholders as the beneficial owners of the right to receive payments under the Interest Cap Agreement and the Class X Certificateholders as obligated to make payments under the Interest Cap Agreement pursuant to Section 6.05(b)(viii) and (ix), and (ii) the portion of the Trust Fund holding the regular interests in any Trust the Upper-Tier REMIC (within represented by the meaning Class A Certificates and the Class UT1, Class UT2, Class UT3 and Class UT4 Interests represented by the Class X Certificates, together with the Interest Cap Agreement as a grantor trust under Subpart E of Section 860G Part 1 of Subchapter J of Chapter 1 of Subtitle A of the Code) other than . The Trustee shall separately report all amounts received or paid by Class A and Class X Certificateholders, respectively, under the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest and the interests represented by the CertificatesCap Agreement in a manner consistent with their status as grantor trust payments.

REMIC Administration. (a) The Trustee Trust Administrator shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return (including Form 8811) or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued, copies of which forms and returns shall promptly be furnished by the Trust Administrator to the NIMS Insurer. For the purposes of the REMIC election in respect of REMIC I0A, the REMIC I 0A Regular Interests shall be designated as the Regular Interests in REMIC I 0A and the Class R-I R-0A Interest shall be designated as the Residual Interest in REMIC I. The 0A. For the purposes of the REMIC II election in respect of REMIC 0B, the REMIC 0B Regular Interests shall be designated as the Regular Interests in REMIC II 0B, and the Class R-II R-0B Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates0B. For the purposes of the REMIC election in respect of REMIC 1A, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest REMIC 1A Regular Interests shall be designated as the Regular Interests in REMIC III 1A and the Class R-III R-1A Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates 1A. For the purposes of the REMIC election in respect of REMIC 1B, the REMIC 1B Regular Interests shall be designated as the Regular Interests in REMIC IV 1B, and the Class R-IV R-1B Interest shall be designated as the Residual Interest in REMIC IV1B. For the purposes of the REMIC election in respect of REMIC 2, the REMIC 2 Regular Interests shall be designated as the Regular Interest in REMIC 2 and the Class R-2 Interest shall be designated as the Residual Interests in REMIC 2. The For the purposes of the REMIC election in respect of REMIC 3, (i) the Regular Certificates (other than the Class C Certificates and the Class P Certificates) and the REMIC 3 Uncertificated Regular Interests shall be designated as the Regular Interests in REMIC 3 and (ii) the Class R-3 Interest shall be designated as the Residual Interest in REMIC 3. For the purposes of the REMIC election in respect of REMIC X, the Class C Certificates and the Class P Certificates shall be designated as the Regular Interests in REMIC V X and the Class R-V X Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO X. Neither the Trustee nor the Trust Administrator shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “"interests” " in any Trust REMIC 0A, REMIC 0B, REMIC 1A, REMIC 1B, REMIC 2, REMIC 3 or REMIC X (within the meaning of Section 860G of the Code) other than the REMIC I 0A Regular Interests, REMIC 0B Regular Interests, REMIC 1A Regular Interests, the REMIC II 1B Regular Interests, the Class CE InterestREMIC 2 Regular Interests, the Class P Interest, the Swap-IO Interest REMIC 3 Uncertificated Regular Interests and the interests represented by the Certificates.

REMIC Administration. (a) It is intended that the Trust Fund shall constitute and that the affairs of the Trust Fund shall be conducted so that each Trust REMIC shall qualify as a REMIC. The Trustee shall act as agent and the Trustee is hereby appointed to act as agent on behalf of the Trust Fund and in such capacity it shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will shall be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC Ieach Trust REMIC, (i) the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the sole class of Residual Interest in REMIC I. The I, (ii) the REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the sole class of Residual Interest in REMIC II. The Class A Certificates, (iii) the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest REMIC III Regular Interests shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the sole class of Residual Interest in REMIC III. The CE Certificates , (iv) the Class C Interest shall be designated as the Regular Interests Interest in REMIC IV and the Class R-IV Interest shall be designated as the sole class of Residual Interest in REMIC IV. The , (v) the Class P Certificates Interest shall be designated as the Regular Interests Interest in REMIC V and the Class R-V Interest shall be designated as the sole class of Residual Interest in REMIC V. V, and (vi) the REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the sole class of Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “interests” in any Trust REMIC (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest Interests and the interests Regular Interests represented by the Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Trustee Paying Agent to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account, the Insurance Policies and any REO Properties as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as a separate class of "regular interests" in the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole class of "residual interests" in the REMIC IV and I. Neither the Class R-IV Interest Trustee nor the Paying Agent shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I, REMIC II and REMIC III Regular Interests and the Residual Certificates. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular InterestsInterests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interest is issued. For the purposes of such election, the REMIC II Regular InterestsInterests shall be designated as the "regular interests" in REMIC II and the Class R-II Certificates shall be designated as the sole class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class CE X-0, Xxxxx X-0, Class X, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class I, Class J, Class K, Class L and Class M Certificates, together with the REMIC III Class N Regular Interest, shall be designated as the "regular interests" in REMIC III and the Class P Interest, R-III Certificates shall be designated as the Swap-IO Interest and the interests represented by the Certificatessole class of "residual interests" in REMIC III.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return (including Form 8811) or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued, copies of which forms and returns shall promptly be furnished by the Trustee to the NIMS Insurer. For the purposes of the REMIC election in respect of REMIC I1, the REMIC I 1 Regular Interests shall be designated as the Regular Interests in REMIC I 1 and the Class R-I R-1 Interest shall be designated as the Residual Interest in REMIC I. The 1. For the purposes of the REMIC II election in respect of REMIC 2, the REMIC 2 Regular Interests shall be designated as the Regular Interests in REMIC II 2 and the Class R-II R-2 Interest shall be designated as the Residual Interest in REMIC II2. The Class A CertificatesFor the purposes of the REMIC election in respect of REMIC 3, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest REMIC 3 Regular Interests shall be designated as the Regular Interests in REMIC III 3 and the Class R-III R-3 Interest shall be designated as the Residual Interest in REMIC III3. The CE For the purposes of the REMIC election in respect of REMIC 4, (i) the Regular Certificates (other than the Class C Certificates and the Class P Certificates) and the REMIC 4 Regular Interests shall be designated as the Regular Interests in REMIC 4 and (ii) the Class R-4 Interest shall be designated as the Residual Interest in REMIC 4. For the purposes of the REMIC election in respect of REMIC CX, the Class C Certificates shall be designated as the Regular Interests in REMIC IV CX and the Class R-IV CX Interest shall be designated as the Residual Interest in REMIC IVCX. The For purposes of the REMIC election in respect of REMIC PX, the Class P Certificates shall be designated as the Regular Interests in REMIC V PX and the Class R-V PX Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VIPX. The Trustee shall not permit the creation of any “"interests” " in any Trust REMIC 1, REMIC 2, REMIC 3, REMIC 4, REMIC CX or REMIC PX (within the meaning of Section 860G of the Code) other than the REMIC I 1 Regular Interests, the REMIC II 2 Regular Interests, the Class CE InterestREMIC 3 Regular Interests, the Class P Interest, the Swap-IO Interest REMIC 4 Regular Interests and the interests represented by the Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return (including Form 8811) or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued, copies of which forms and returns shall promptly be furnished by the Trustee to the NIMS Insurer. For the purposes of the REMIC election in respect of REMIC I1, the REMIC I 1 Regular Interests shall be designated as the Regular Interests in REMIC I 1 and the Class R-I R‑1 Interest shall be designated as the Residual Interest in REMIC I. The 1. For the purposes of the REMIC II election in respect of REMIC 2, the REMIC 2 Regular Interests shall be designated as the Regular Interests in REMIC II 2 and the Class R-II R-2 Interest shall be designated as the Residual Interest in REMIC II2. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest REMIC 3 Regular Interests shall be designated as the Regular Interests in REMIC III 3 and the Class R-III R-3 Interest shall be designated as the Residual Interest in REMIC III3. The CE For the purposes of the REMIC election in respect of REMIC CX, the Class C Certificates shall be designated as the Regular Interests in REMIC IV CX and the Class R-IV R‑CX Interest shall be designated as the Residual Interest in REMIC IVCX. The For the purposes of the REMIC election in respect of REMIC PX, the Class P Certificates shall be designated as the Regular Interests in REMIC V PX and the Class R-V R‑PX Interest shall be designated as the Residual Interest in REMIC V. PX. For the purposes of the REMIC VI Regular election in respect of REMIC SwapX, the Class Swap IO Upper-Tier Interest SWAP-IO shall be designated as the Regular Interest Interests in REMIC VI SwapX and the Class R-VI SwapX Interest shall be designated as the Residual Interest in REMIC VI. SwapX. The Trustee shall not permit the creation of any “interests” in any Trust REMIC 1, REMIC 2, REMIC 3, REMIC 4, REMIC CX, REMIC SwapX or REMIC PX (within the meaning of Section 860G of the Code) other than the REMIC I 1 Regular Interests, the REMIC II 2 Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest REMIC 3 Regular Interests and the interests represented by the Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each that the Trust REMIC Fund be treated as a REMIC under the Code and, if necessary, under two separate REMICs for federal and any applicable state lawand local income tax purposes. Each such election The Class R Certificates will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day represent beneficial ownership of the calendar year in which the Certificates are issuedClass R1 Interest and Class R2 Interest. For the purposes The Owner of the REMIC election in respect Class R Certificate representing the largest Percentage Interest of REMIC I, the REMIC I Regular Interests shall be Residual Certificates is hereby designated as the Regular Interests "tax matters person" as defined in the REMIC I Provisions (the "Tax Matters Person") with respect to each of REMIC 1 and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II2. The Trustee shall treat each Class of Offered Certificates as a regular interest with a principal balance equal to the applicable Class Certificate Principal Balance for such Distribution Date plus Basis Risk Shortfalls for such Distribution Date and, in the case of the Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE right to receive Supplemental Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VIPayments. The Trustee shall not permit treat the creation Certificateholder's right to receive payments of Basis Risk Shortfall and in the case of the Class A Certificates, the right to receive Supplemental Interest Payments as an interest rate cap agreement (the "Cap Agreement") that the Trustee holds separate and apart from the portion of the Offered Certificates treated as a REMIC regular interest and shall treat each Offered Certificateholder as owning the portion of the Offered Certificate treated as a REMIC regular interest issued by REMIC 2 and the Cap Agreement through a trust treated as a grantor trust under subpart E of part I of subchapter J of Chapter 1 of subtitle A of the Code. Notwithstanding any “interests” in any Trust REMIC (other provision of this Agreement, the Basis Risk Reserve Fund shall be treated as an outside reserve fund within the meaning of Treasury Regulation Section 860G 1.860G-2(h) and not an asset of any REMIC created pursuant to this Agreement, the owners of the CodeBasis Risk Reserve Fund shall be the owner(s) other than the REMIC I Regular Interests, the REMIC II Regular Interests, of the Class CE InterestX Certificates, and for all federal tax purposes, amounts transferred by REMIC 2 to the Basis Risk Reserve Fund shall be treated as distributed by REMIC 2 to the owner(s) of the Class P InterestX Certificates and owners of the Class X Certificates, shall include as income their pro rata share of the Swap-IO Interest and income of such fund including income from the regular interests ownership of which is represented by the Class X Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Each such Such election will be made by the Trust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC IA, the REMIC I A Regular Interests shall be designated as the Regular Interests in REMIC I A and the Class R-I A Residual Interest shall be designated as the Residual Interest Interests in REMIC I. The A. For the purposes of the REMIC II election in respect of REMIC B, the REMIC B Regular Interests shall be designated as the Regular Interests in REMIC II B and the Class R-II B Residual Interest shall be designated as the Residual Interests in REMIC B. For the purposes of the REMIC election in respect of REMIC C, the Certificates or Components thereof (other than the Class R Certificates), shall be designated as the Regular Interests in REMIC C and the Class R-C Residual Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, C. Neither the Mezzanine Certificates, Trustee nor the Swap-IO Interest, the Class CE Interest and the Class P Interest Trust Administrator shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “interests” in any Trust REMIC A, REMIC B or REMIC C (within the meaning of Section 860G of the Code) other than the REMIC I A Regular Interests, the REMIC II B Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest Interests and the interests represented Certificates. The Trustee shall elect to treat each REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Such election will be made by the CertificatesTrust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Each such Such election will be made by the Trust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I-A, the REMIC I I-A Regular Interests shall be designated as the Regular Interests in REMIC I I-A and the Class R-I IA Residual Interest shall be designated as the Residual Interests in REMIC I-A. For the purposes of the REMIC election in respect of REMIC I-B, the Group 1 Certificates (other than the Class 1-R Certificates) shall be designated as the Regular Interests in REMIC I-B and the Class R-IB Residual Interest shall be designated as the Residual Interest in REMIC I. The REMIC II Regular Interests I-B. Neither the Trustee nor the Trust Administrator shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “interests” in any Trust REMIC I-A or REMIC I-B (within the meaning of Section 860G of the Code) other than the REMIC I I-A Regular InterestsInterests and the Group 1 Certificates. For the purposes of the REMIC election in respect of REMIC II-A, the REMIC II II-A Regular InterestsInterests shall be designated as the Regular Interests in REMIC II-A and the Class R-IIA Residual Interest shall be designated as the Residual Interests in REMIC II-A. For the purposes of the REMIC election in respect of REMIC II-B, the Group 2 Certificates (other than the Class CE Interest2-R Certificates) shall be designated as the Regular Interests in REMIC II-B and the Class R-IIB Residual Interest shall be designated as the Residual Interest in REMIC II-B. Neither the Trustee nor the Trust Administrator shall permit the creation of any “interests” in REMIC II-A or REMIC II-B (within the meaning of Section 860G of the Code) other than the REMIC II-A Regular Interests and the Group 2 Certificates. For the purposes of the REMIC election in respect of REMIC II-C, the Group 2 Certificates (other than the Class P Interest, 2-R Certificates) shall be designated as the SwapRegular Interests in REMIC II-IO Interest C and the interests represented Class R-IIC Residual Interest shall be designated as the Residual Interest in REMIC II-C. The Trustee shall elect to treat each REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Such election will be made by the CertificatesTrust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Each such Such election will be made by the Trust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I-A, the REMIC I I-A Regular Interests shall be designated as the Regular Interests in REMIC I I-A and the Class R-I IA Interest shall be designated as the Residual Interest Interests in REMIC I. The I-A. For the purposes of the REMIC II election in respect of REMIC I-B, the REMIC I-B Regular Interests shall be designated as the Regular Interests in REMIC II I-B and the Class R-II IB Interest shall be designated as the Residual Interest in REMIC II. The Class A CertificatesI-B. For the purposes of the REMIC election in respect of REMIC I-C, the Mezzanine Certificates, the Swap-IO Interest, Group 1 Certificates (other than the Class CE Interest and the Class P Interest 1-R Certificates) shall be designated as the Regular Interests in REMIC III I-C and the Class R-III IC Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates I-C. Neither the Trustee nor the Trust Administrator shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “interests” in any Trust REMIC I-A, REMIC I-B or REMIC I-C (within the meaning of Section 860G of the Code) other than the REMIC I I-A Regular Interests, the REMIC II I-B Regular InterestsInterests and the Group 1 Certificates. For the purposes of the REMIC election in respect of REMIC II-A, the REMIC II-A Regular Interests shall be designated as the Regular Interests in REMIC II-A and the Class CE InterestR-IIA Interest shall be designated as the Residual Interests in REMIC II-A. For the purposes of the REMIC election in respect of REMIC II-B, the Group 2 Certificates (other than the Class P Interest, 2-R Certificates) shall be designated as the SwapRegular Interests in REMIC II-IO Interest B and the interests represented Class R-IID Interest shall be designated as the Residual Interest in REMIC II-B. Neither the Trustee nor the Trust Administrator shall permit the creation of any “interests” in REMIC II-A or REMIC II-B (within the meaning of Section 860G of the Code) other than the REMIC II-A Regular Interests and the Group 2 Certificates. The Trustee shall elect to treat each REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Such election will be made by the CertificatesTrust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Each such Such election will be made by the Trust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I-A, the REMIC I I-A Regular Interests shall be designated as the Regular Interests in REMIC I I-A and the Class R-I IA Residual Interest shall be designated as the Residual Interest Interests in REMIC I. The I-A. For the purposes of the REMIC II election in respect of REMIC I-B, the REMIC I-B Regular Interests shall be designated as the Regular Interests in REMIC II I-B and the Class R-II IB Residual Interest shall be designated as the Residual Interests in REMIC I-B. For the purposes of the REMIC election in respect of REMIC I-C, the Group 1 Certificates (other than the Class 1-R Certificates) shall be designated as the Regular Interests in REMIC I-C and the Class R-IC Residual Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, I-C. Neither the Mezzanine Certificates, Trustee nor the Swap-IO Interest, the Class CE Interest and the Class P Interest Trust Administrator shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “interests” in any Trust REMIC I-A, REMIC I-B or REMIC I-C (within the meaning of Section 860G of the Code) other than the REMIC I I-A Regular Interests, REMIC I-B Regular Interests and the Group 1 Certificates. For the purposes of the REMIC II election in respect of REMIC II-A, the REMIC II-A Regular Interests shall be designated as the Regular Interests in REMIC II-A and the Class R-IIA Residual Interest shall be designated as the Residual Interests in REMIC II-A. For the purposes of the REMIC election in respect of REMIC II-B, the REMIC II-B Regular Interests shall be designated as the Regular Interests in REMIC II-B and the Class R-IIB Residual Interest shall be designated as the Residual Interests in REMIC II-B. For the purposes of the REMIC election in respect of REMIC II-C, the Group 2 Certificates (other than the Class 2-R Certificates) shall be designated as the Regular Interests in REMIC II-C and the Class R-IIC Residual Interest shall be designated as the Residual Interest in REMIC II-C. Neither the Trustee nor the Trust Administrator shall permit the creation of any “interests” in REMIC II-A, REMIC II-B or REMIC II-C (within the meaning of Section 860G of the Code) other than the REMIC II-A Regular Interests, the Class CE Interest, the Class P Interest, the SwapREMIC II-IO Interest B Regular Interests and the interests represented Group 2 Certificates. The Trustee shall elect to treat each REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Such election will be made by the CertificatesTrust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Trustee Paying Agent to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account, the Insurance Policies and any REO Properties as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as a separate class of "regular interests" in the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The CE Certificates shall be designated as the Regular Interests sole class of "residual interests" in the REMIC IV and I. Neither the Class R-IV Interest Trustee nor the Paying Agent shall be designated as the Residual Interest in REMIC IV. The P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Trustee shall not permit the creation of any “"interests” in any Trust REMIC " (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I, REMIC II and REMIC III Regular Interests and the Residual Certificates. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular InterestsInterests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interest is issued. For the purposes of such election, the REMIC II Regular InterestsInterests shall be designated as the "regular interests" in REMIC II and the Class R-II Certificates shall be designated as the sole class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class CE InterestX-0, Xxxxx X-0, Class X, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class I, Class J, Class K and Class L Certificates, together with the REMIC III Class P Interest, the Swap-IO M Regular Interest and the interests represented by REMIC III Excess Interest, shall be designated as the Certificates"regular interests" in REMIC III and the Class R-III Certificates shall be designated as the sole class of "residual interests" in REMIC III.