REMIC Opinion. An Opinion of Independent Counsel, to the effect that the proposed action described therein would not, under the REMIC Provisions, (i) cause REMIC I or REMIC II to fail to qualify as a REMIC while any regular interest in such REMIC is outstanding, (ii) result in a tax on prohibited transactions with respect to any REMIC or (iii) constitute a taxable contribution to any REMIC after the Startup Day.
Appears in 4 contracts
Samples: Trust, Pooling and Servicing Agreement (Thornburg Mortgage Securities Trust 2004-4), Trust, Pooling and Servicing Agreement (Structured Asset Mortgage Investments Inc), Trust, Pooling and Servicing Agreement (Structured Asset Mortgage Investments Inc)
REMIC Opinion. An Opinion of Independent Counsel, Counsel to the effect that the proposed action described therein would not, under the REMIC Provisions, (i) cause any REMIC I or REMIC II to fail to qualify as a REMIC while any regular interest in such REMIC is outstanding, (ii) result in a tax on prohibited transactions with respect to any REMIC or (iii) constitute a taxable contribution to any REMIC after the Startup Day.
Appears in 3 contracts
Samples: Pooling and Servicing Agreement (Bankunited Trust 2005-1, Mortgage Pass-Through Certificates, Series 2005-1), Pooling and Servicing Agreement (Prime Mortgage Trust 2006-1), Pooling and Servicing Agreement (Prime Mortgage Trust 2007-1)
REMIC Opinion. An Opinion of Independent Counsel, to the effect that the proposed action described therein would not, under the REMIC Provisions, (i) cause any REMIC I or REMIC II to fail to qualify as a REMIC while any regular interest in such REMIC is outstanding, (ii) result in a tax on prohibited transactions with respect to any REMIC or (iii) constitute a taxable contribution to any REMIC after the Startup Day.
Appears in 3 contracts
Samples: Pooling and Servicing Agreement (Bear Stearns Arm Trust 2005-12), Pooling and Servicing Agreement (Bear Stearns Arm Trust, Mortgage Pass-Through Certificates, Series 2005-6), Pooling and Servicing Agreement (Bear Stearns Arm Trust, Mortgage Pass-Through Certificates, Series 2005-11)
REMIC Opinion. An Opinion of Independent Counsel, to the effect that the proposed action described therein would not, under the REMIC Provisions, (i) cause any of REMIC I I, REMIC II or REMIC II to fail III to qualify as a REMIC while any regular interest in any such REMIC is outstanding, (ii) result in a tax on prohibited transactions with respect to any REMIC or (iii) constitute a taxable contribution to any REMIC after the Startup Day.
Appears in 2 contracts
Samples: Pooling and Servicing Agreement (Bear Stearns Asset Backed Securities Inc), Pooling and Servicing Agreement (Bear Stearns Asset Backed Sec Inc Series 2004 1)
REMIC Opinion. An Opinion of Independent Counsel, to the effect that the proposed action described therein would not, under the REMIC Provisions, (i) cause either REMIC I or REMIC II to fail to qualify as a REMIC while any regular interest in such REMIC is outstanding, (ii) result in a tax on prohibited transactions with respect to any REMIC or (iii) constitute a taxable contribution to any REMIC after the Startup Day.
Appears in 2 contracts
Samples: Pooling and Servicing Agreement (Structured Asset Mortgage Investments Inc), Pooling and Servicing Agreement (Structured Asset Mortgage Investments Inc)
REMIC Opinion. An Opinion of Independent Counsel, to the effect that the proposed action described therein would not, under the REMIC Provisions, (i) cause any 2005-2 REMIC I or REMIC II to fail to qualify as a REMIC while any regular interest in such 2005-2 REMIC is outstanding, (ii) result in a tax on prohibited transactions with respect to any 2005-2 REMIC or (iii) constitute a taxable contribution to any 2005-2 REMIC after the Startup Day.
Appears in 1 contract
Samples: Pooling and Servicing Agreement (Structured Asset Mort Inv Ii Inc Bear Stearns Alt a Tr 05 2)
REMIC Opinion. An Opinion of Independent Counsel, to the effect that the proposed action described therein would not, under the REMIC Provisions, (i) cause REMIC I I, REMIC II or REMIC II III to fail to qualify as a REMIC while any regular interest in such REMIC is outstanding, (ii) result in a tax on prohibited transactions with respect to any REMIC or (iii) constitute a taxable contribution to any REMIC after the Startup Day.
Appears in 1 contract
Samples: Trust, Pooling and Servicing Agreement (Thornburg Mortgage Securities Trust 2005-4)
REMIC Opinion. An Opinion of Independent Counsel, Counsel to the effect that the proposed action described therein would not, under the REMIC Provisions, (i) cause REMIC I I, REMIC II or REMIC II III to fail to qualify as a REMIC while any regular interest in such REMIC is outstanding, (ii) result in a tax on prohibited transactions with respect to any REMIC I, REMIC II or REMIC III or (iii) constitute a taxable contribution to any REMIC I, REMIC II or REMIC III after the Startup Day.
Appears in 1 contract
Samples: Pooling and Servicing Agreement (Prime Mortgage Trust 2007-3)
REMIC Opinion. An Opinion of Independent Counsel, to the effect that the proposed action described therein would not, under the REMIC Provisions, (i) cause any of REMIC I I, REMIC II or REMIC II III to fail to qualify as a REMIC while any regular interest in any such REMIC is outstanding, (ii) result in a tax on prohibited transactions with respect to any REMIC or (iii) constitute a taxable contribution to any REMIC after the Startup Day.
Appears in 1 contract
Samples: Pooling and Servicing Agreement (Bear Stearns Asset Backed Securities Trust 2004-2)
