Common use of Title, Management and Disposition of REO Property Clause in Contracts

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1, shall sell any REO Property as soon as practicable and in any event no later than the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Servicer shall have delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Master Servicer, on behalf of REMIC 1the Trust Fund, shall either sell any REO Property as soon as practicable and in any event no later than before the end close of the third full taxable year after following the taxable year in which such REMIC the Trust Fund acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the above three-year grace period would otherwise expire, an extension of such the above three-year grace period, unless the Master Servicer shall have delivered to the Trustee Trustee, the Trust Administrator and the Depositor an Opinion of Counsel, addressed to the Trustee Trustee, the Trust Administrator and the Depositor, to the effect that the holding by the REMIC Trust Fund of such REO Property subsequent to three years the close of the third taxable year after its acquisition will not result in the imposition on the REMIC Trust Fund of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder Trust REMIC to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder Trust REMIC of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1, shall sell any REO Property as soon as practicable and in any event no later than the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Servicer shall have delivered to the Trustee and the NIMS Insurer an Opinion of Counsel, Counsel acceptable to the NIMS Insurer and addressed to the Trustee Trustee, the NIMS Insurer and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders, subject to applicable laws. The Trustee’s name shall be placed on the title to such REO Property solely as the Trustee hereunder and not in its individual capacity. The Servicer shall ensure that the title to such REO Property references this Agreement and the Trustee’s capacity hereunder. The Servicer, on behalf of REMIC 1the Trust Fund (and on behalf of the Trustee for the benefit of the Certificateholders), shall either sell any REO Property as soon as practicable and in any event no later than before the end close of the third full taxable year after the taxable year in which such REMIC the Trust Fund acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such the three-year grace period, unless the Servicer shall have delivered to the Trustee and the Depositor an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC Trust Fund of such REO Property subsequent to three years after its acquisition will not result in the imposition on the any REMIC created hereunder of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs REMIC created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs REMIC created hereunder of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject related to applicable laws, a Mortgage Loan shall be taken in the name of the Trustee, or its nominee, in trust on behalf of the Trust Fund and for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than by the end close of the third full taxable calendar year after following the taxable calendar year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8860(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 sixty (60) days before the day on which the three-year grace period would otherwise expire, expire an extension of such the three-year grace period, unless the Servicer shall have had delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three (3) years after its acquisition will not result in the imposition on the any Trust REMIC created hereunder of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs created Trust REMIC hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs Trust REMIC created hereunder of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders, subject to applicable laws. The Servicer, on behalf of REMIC 1the Trust Fund (and on behalf of the Trustee for the benefit of the Certificateholders), shall either sell any REO Property as soon as practicable and in any event no later than before the end close of the third full taxable year after the taxable year in which such REMIC the Trust Fund acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such the three-year grace period, unless the Servicer shall have delivered to the Trustee and the Depositor an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC Trust Fund of such REO Property subsequent to three years after its acquisition will not result in the imposition on the any REMIC created hereunder of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs REMIC created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs REMIC created hereunder of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject related to applicable laws, a Mortgage Loan shall be taken in the name of the Trustee, or its nominee, in trust on behalf of the Trust Fund and for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than by the end close of the third full taxable calendar year after following the taxable calendar year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8860(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 sixty (60) days before the day on which the three-year grace period would otherwise expire, an extension of such the three-year grace period, unless the Servicer shall have had delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three (3) years after its acquisition will not result in the imposition on the any Trust REMIC created hereunder of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs created Trust REMIC hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs Trust REMIC created hereunder of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust on behalf of the Trust Fund and for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than prior to the end of the third full taxable year after the taxable year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such the three-year grace period, unless the Servicer shall have delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three years after its acquisition will not result in the imposition on the any Trust REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder Trust REMIC to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder Trust REMIC of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1, shall sell any REO Property as soon as practicable and in any event no later than the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Servicer shall have delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Master Servicer, on behalf of REMIC 1, shall sell any REO Property as soon as practicable practical and in any event no later than the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Master Servicer shall have delivered to the Trustee and the NIMS Insurer an Opinion of Counsel, Counsel acceptable to the NIMS Insurer and addressed to the Trustee Trustee, the NIMS Insurer and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Master Servicer, on behalf of REMIC 1I (and on behalf of the Trustee for the benefit of the Certificateholders), shall either sell any REO Property as soon as practicable and in any event no later than before the end close of the third full taxable year after the taxable year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such the three-year grace period, unless the Master Servicer shall have delivered to the Trustee and the Depositor an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC I, REMIC II or REMIC III of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder REMIC I, REMIC II or REMIC III to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder REMIC I, REMIC II or REMIC III of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the CertificateholdersCertificateholders and the Certificate Insurer. The Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than the end of the third full taxable year within three years after the taxable year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such the three-year grace period, unless the Servicer shall have delivered to the Trust Administrator and the Trustee an Opinion of Counsel, addressed to the Trustee Trust Administrator, the Trustee, the Certificate Insurer and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC I, REMIC II or REMIC III of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder REMIC I, REMIC II or REMIC III to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder REMIC I, REMIC II or REMIC III of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Master Servicer, on behalf of REMIC 1the Trust Fund, shall either sell any REO Property as soon as practicable and in any event no later than within three years after the end of the third full taxable year after the taxable calendar year in which such REMIC the Trust Fund acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such the three-year grace period, unless the Master Servicer shall have delivered to the Trustee and the Depositor an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC Trust Fund of such REO Property subsequent to three years the three-year grace period after its acquisition will not result in the imposition on the REMIC Trust Fund of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder Trust Fund to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder Trust Fund of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Master Servicer, on behalf of REMIC 1, shall either sell any REO Property as soon as practicable and in any event no later than by the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Master Servicer shall have delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1the Trust Fund, shall either sell any REO Property as soon as practicable and in any event no later than before the end close of the third full taxable year after following the taxable year in which such REMIC the Trust Fund acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the above three-year grace period would otherwise expire, an extension of such the above three-year grace period, unless the Servicer shall have delivered to the Trustee Trustee, the Trust Administrator and the Depositor an Opinion of Counsel, addressed to the Trustee Trustee, the Trust Administrator and the Depositor, to the effect that the holding by the REMIC Trust Fund of such REO Property subsequent to three years the close of the third taxable year after its acquisition will not result in the imposition on the REMIC Trust Fund of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder Trust REMIC to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder Trust REMIC of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Master Servicer, on behalf of REMIC 1, shall sell any REO Property as soon as practicable practical and in any event no later than the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Master Servicer shall have delivered to the Trustee and the NIMS Insurer an Opinion of Counsel, Counsel acceptable to the NIMS Insurer and addressed to the Trustee Trustee, the NIMS Insurer and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1, shall sell any REO Property as soon as practicable practical and in any event no later than the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Servicer shall have delivered to the Trustee and the NIMS Insurer an Opinion of Counsel, Counsel acceptable to the NIMS Insurer and addressed to the Trustee Trustee, the NIMS Insurer and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Master Servicer, on behalf of REMIC 1the Trust Fund, shall either sell any REO Property as soon as practicable and in any event no later than before the end close of the third full taxable year after following the taxable year in which such REMIC the Trust Fund acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the above three-year grace period would otherwise expire, an extension of such the above three-year grace period, unless the Master Servicer shall have delivered to the Trustee Trustee, the Trust Administrator and the Depositor an Opinion of Counsel, addressed to the Trustee Trustee, the Trust Administrator and the Depositor, to the effect that the holding by the REMIC Trust Fund of such REO Property subsequent to three years the close of the third taxable year after its acquisition will not result in the imposition on the REMIC Trust Fund of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder Trust REMIC to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder Trust REMIC of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, Trust or its nominee, in trust for the benefit of the Certificateholders, subject to applicable laws. The Servicer, on behalf of REMIC 1the Trust Fund (and on behalf of the Trustee for the benefit of the Certificateholders), shall either sell any REO Property as soon as practicable and in any event no later than before the end close of the third full taxable year after the taxable year in which such REMIC the Trust Fund acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such the three-year grace period, unless the Servicer shall have delivered to the Trustee and the Depositor an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC Trust Fund of such REO Property subsequent to three years after its acquisition will not result in the imposition on the any REMIC created hereunder of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs REMIC created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs REMIC created hereunder of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1the Trust Fund, shall either sell any REO Property as soon as practicable and in any event no later than before the end close of the third full taxable year after following the taxable year in which such REMIC the Trust Fund acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the above three-year grace period would otherwise expire, an extension of such the above three-year grace period, unless the Servicer shall have delivered to the Trustee Trustee, the Trust Administrator and the Depositor an Opinion of Counsel, addressed to the Trustee Trustee, the Trust Administrator and the Depositor, to the effect that the holding by the REMIC Trust Fund of such REO Property subsequent to three years the close of the third taxable year after its acquisition will not result in the imposition on the REMIC Trust Fund of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder Trust REMIC to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder Trust REMIC of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Master Servicer, on behalf of REMIC 1I, shall sell any REO Property as soon as practicable practical and in any event no later than the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Master Servicer shall have delivered to the Trustee and the NIMS Insurer an Opinion of Counsel, Counsel acceptable to the NIMS Insurer and addressed to the Trustee Trustee, the NIMS Insurer and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Master Servicer, on behalf of REMIC 1, shall sell any REO Property as soon as practicable practical and in any event no later than the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Master Servicer shall have delivered to the Trustee and the NIMS Insurer an Opinion of Counsel, addressed to the Trustee Trustee, the NIMS Insurer and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1, shall sell any REO Property as soon as practicable and in any event no later than the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Servicer shall have delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1I, shall sell any REO Property as soon as practicable practical and in any event no later than the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Servicer shall have delivered to the Trustee and the NIMS Insurer an Opinion of Counsel, Counsel acceptable to the NIMS Insurer and addressed to the Trustee Trustee, the NIMS Insurer and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Master Servicer, on behalf of REMIC 1I (and on behalf of the Trustee for the benefit of the Certificateholders), shall either sell any REO Property as soon as practicable and in any event no later than the end of the third full taxable year within two years after the taxable year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the threetwo-year grace period would otherwise expire, an extension of such threethe two-year grace period, unless the Master Servicer shall have delivered to the Trustee and the Depositor an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three two years after its acquisition will not result in the imposition on the REMIC I, REMIC II or REMIC III of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder REMIC I, REMIC II or REMIC III to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder REMIC I, REMIC II or REMIC III of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust on behalf of the Trust Fund and for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than by the end close of the third full taxable calendar year after following the taxable calendar year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8860(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, expire an extension of such the three-year grace period, unless the Servicer shall have had delivered to the Trust Administrator and the Trustee an Opinion of Counsel, addressed to the Trust Administrator, the Trustee and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three years after its acquisition will not result in the imposition on the any Trust REMIC created hereunder of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created Trust REMIC hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs Trust REMIC created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1, shall sell any REO Property as soon as practicable and in any event no later than the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Servicer shall have delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Master Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than the end of the third full taxable year within three years after the taxable year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such the three-year grace period, unless the Master Servicer shall have delivered to the Trust Administrator and the Trustee an Opinion of Counsel, addressed to the Trust Administrator, the Trustee and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC I, REMIC II or REMIC III of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder REMIC I, REMIC II or REMIC III to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder REMIC I, REMIC II or REMIC III of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders, subject to applicable laws. The Trustee’s name shall be placed on the title to such REO Property solely as the Trustee hereunder and not in its individual capacity. The Servicer shall ensure that the title to such REO Property references this Agreement and the Trustee’s capacity hereunder. The Servicer, on behalf of REMIC 1the Trust Fund (and for the benefit of the Certificateholders), shall either sell any REO Property as soon as practicable and in any event no later than before the end close of the third full taxable year after the taxable year in which such REMIC the Trust Fund acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such the three-year grace period, unless the Servicer shall have delivered to the Trustee and the Master Servicer and the Depositor an Opinion of Counsel, addressed to the Trustee and the Master Servicer and the Depositor, to the effect that the holding by the REMIC Trust Fund of such REO Property subsequent to three years after its acquisition will not result in the imposition on the any REMIC created hereunder of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs REMIC created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs REMIC created hereunder of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Master Servicer, on behalf of REMIC 1, shall either sell any REO Property as soon as practicable and in any event no later than by the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Master Servicer shall have delivered to the Trustee and the NIMs Insurer an Opinion of Counsel, addressed to the Trustee Trustee, the NIMs Insurer and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1, shall sell any REO Property as soon as practicable and in any event no later than the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Servicer shall have delivered to the Trustee and the Trust Administrator an Opinion of Counsel, addressed to the Trustee Trustee, the Trust Administrator and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 12, shall sell any REO Property as soon as practicable practical and in any event no later than the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Servicer shall have delivered to the Trustee and the NIMS Insurer an Opinion of Counsel, Counsel acceptable to the NIMS Insurer and addressed to the Trustee Trustee, the NIMS Insurer and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1I, shall sell any REO Property as soon as practicable practical and in any event no later than the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Servicer shall have delivered to the Trustee and the NIMS Insurer an Opinion of Counsel, Counsel acceptable to the NIMS Insurer and addressed to the Trustee Trustee, the NIMS Insurer and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the CertificateholdersCertificateholders and the Certificate Insurer. The Master Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than by the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Master Servicer shall have delivered to the Trustee an Opinion of Counsel, addressed to the Trustee Trustee, the Certificate Insurer and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder either REMIC I or REMIC II to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder either REMIC I or REMIC II of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Master Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than the end of the third full taxable year within three years after the taxable year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such the three-year grace period, unless the Master Servicer shall have delivered to the Trust Administrator and the Trustee an Opinion of Counsel, addressed to the Trust Administrator, the Trustee and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC I, REMIC II or REMIC III of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder REMIC I, REMIC II or REMIC III to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder REMIC I, REMIC II or REMIC III of any "income from non-non- permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Master Servicer, on behalf of REMIC 1the Trust Fund and consistent with the servicing standard set forth in Section 3.01, shall either sell any REO Property as soon as practicable and in any event no later than before the end close of the third full taxable year after following the taxable year in which such REMIC the Trust Fund acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-three- year grace period would otherwise expire, an extension of such the three-year grace period, unless the Master Servicer shall have delivered to the Trustee and the Depositor an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC Trust Fund of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC I of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder REMIC I to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall shall, consistent with the servicing standard set forth in Section 3.01, manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder REMIC I of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property serviced by Ocwen shall, subject to applicable laws, be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The ServicerOcwen, on behalf of REMIC 1, shall sell any such REO Property as soon as practicable and in any event no later than the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Servicer Ocwen shall have delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer Ocwen shall manage, conserve, protect and operate each REO Property serviced by it for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject related to applicable laws, a Mortgage Loan shall be taken in the name of the Trustee, or its nominee, in trust on behalf of the Trust Fund and for the benefit of the Certificateholders. The related Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than by the end close of the third full taxable calendar year after following the taxable calendar year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8860(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 sixty (60) days before the day on which the three-year grace period would otherwise expire, expire an extension of such the three-year grace period, unless the related Servicer shall have had delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three (3) years after its acquisition will not result in the imposition on the any Trust REMIC created hereunder of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs created Trust REMIC hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The related Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs Trust REMIC created hereunder of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1, shall sell any REO Property as soon as practicable and in any event no later than the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Servicer shall have delivered to the Trustee and the NIMS Insurer an Opinion of Counsel, Counsel acceptable to the NIMS Insurer and addressed to the Trustee Trustee, the NIMS Insurer and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "income from non-non- permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit on behalf of the Certificateholders. The Master Servicer, on behalf of REMIC 1the Trust Fund, shall either sell any REO Property as soon as practicable and in any event no later than the end of the third full taxable year within three years after the taxable year in which such REMIC Trust Fund acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later more than 60 days before the day on which the three-year grace period would otherwise expire, expire an extension of such three-year the grace period, unless the Master Servicer shall have delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, which Opinion of Counsel shall not be at the expense of the Trust Fund or Trustee, to the effect that the holding by the REMIC I of such REO Property subsequent to three years such period after its acquisition will not result in the imposition on the REMIC I, REMIC II or REMIC III of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder REMIC I, REMIC II or REMIC III to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder REMIC I, REMIC II or REMIC III of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject related to applicable laws, a Mortgage Loan shall be taken in the name of the Trustee, or its nominee, in trust on behalf of the Trust Fund and for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than by the end close of the third full taxable [ ] calendar year after following the taxable calendar year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8860(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 [________] ([__]) days before the day on which the three-year [ ]-year grace period would otherwise expire, an extension of such the three-year grace period, unless the Servicer shall have had delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three [________] ([__]) years after its acquisition will not result in the imposition on the any Trust REMIC created hereunder of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs created Trust REMIC hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs Trust REMIC created hereunder of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Master Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than prior to the end of the third full taxable year after the taxable year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such the three-year grace period, unless the Master Servicer shall have delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC I, REMIC II or REMIC III of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder REMIC I, REMIC II or REMIC III to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder REMIC I, REMIC II or REMIC III of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1the Trust Fund (and on behalf of the Trustee for the benefit of the Certificateholders), shall either sell any REO Property as soon as practicable and in any event no later than before the end close of the third full taxable year after the taxable year in which such REMIC the Trust Fund acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such the three-year grace period, unless the Servicer shall have delivered to the Trustee and the Depositor an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC Trust Fund of such REO Property subsequent to three years after its acquisition will not result in the imposition on the any REMIC created hereunder of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder REMIC I, REMIC II or REMIC III to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs REMIC created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1, shall sell any REO Property as soon as practicable and in any event no later than 84 the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Servicer shall have delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The related Servicer, on behalf of REMIC 1the Trust Fund (and on behalf of the Trustee for the benefit of the Certificateholders), shall either sell any related REO Property as soon as practicable and in any event no later than before the end close of the third full taxable year after the taxable year in which such REMIC the Trust Fund acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such the three-year grace period, unless the related Servicer shall have delivered to the Trustee and the Depositor an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC Trust Fund of such REO Property subsequent to three years after its acquisition will not result in the imposition on the any REMIC created hereunder of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder REMIC I, REMIC II or REMIC III to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Each Servicer shall manage, conserve, protect and operate each related REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs REMIC created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject related to applicable laws, a Mortgage Loan shall be taken in the name of the Trustee, or its nominee, in trust on behalf of the Trust Fund and for the benefit of the Certificateholders. The ServicerWxxxx Fargo, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than by the end close of the third full taxable calendar year after following the taxable calendar year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8860(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 sixty (60) days before the day on which the three-year grace period would otherwise expire, expire an extension of such the three-year grace period, unless the Servicer shall have Wxxxx Fargo had delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three (3) years after its acquisition will not result in the imposition on the any Trust REMIC created hereunder of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created Trust REMIC hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer Wxxxx Fargo shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs Trust REMIC created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit on behalf of the Certificateholders. The Master Servicer, on behalf of REMIC 1the Trust Fund, shall either sell any REO Property as soon as practicable and in any event no later than before the end close of the third full taxable year after following the taxable year in which such REMIC the Trust Fund acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later more than 60 days before the day on which the three-year grace period would otherwise expire, expire an extension of such three-year the grace period, unless the Master Servicer shall have delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the DepositorCompany, which Opinion of Counsel shall not be at the expense of the Trust Fund or the Trustee, to the effect that the holding by the REMIC I of such REO Property subsequent to three years such period after its acquisition will not result in the imposition on the REMIC I, REMIC II or REMIC III of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder REMIC I, REMIC II or REMIC III to fail to qualify as a REMIC under Federal federal tax law at any time that any Certificates are outstanding. The Master Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder REMIC I, REMIC II or REMIC III of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1, shall sell any REO Property as soon as practicable and in any event no later than the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) 91 of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Servicer shall have delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust on behalf of the Trust Fund and for the benefit of the 90 Pooling and Servicing Agreement Certificateholders. The Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than by the end close of the third full taxable calendar year after following the taxable calendar year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, expire an extension of such the three-year grace period, unless the Servicer shall have had delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three years after its acquisition will not result in the imposition on the any Trust REMIC created hereunder of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs created Trust REMIC hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs Trust REMIC created hereunder of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Master Servicer, 77 on behalf of REMIC 1the Trust Fund and consistent with the servicing standard set forth in Section 3.01, shall either sell any REO Property as soon as practicable and in any event no later than before the end close of the third full taxable year after following the taxable year in which such REMIC the Trust Fund acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-three- year grace period would otherwise expire, an extension of such the three-year grace period, unless the Master Servicer shall have delivered to the Trustee Trustee, the Trust Administrator and the Depositor an Opinion of Counsel, addressed to the Trustee Trustee, the Trust Administrator and the Depositor, to the effect that the holding by the REMIC Trust Fund of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC I of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder REMIC I to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall shall, consistent with the servicing standard set forth in Section 3.01, manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder REMIC I of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than prior to the end of the third full taxable year after the taxable year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such the three-year grace period, unless the Servicer shall have delivered to the Trustee Trustee, the Certificate Insurer and the Guarantor an Opinion of Counsel, addressed to the Trustee Trustee, the Depositor, the Guarantor and the DepositorCertificate Insurer, to the effect that the holding by the REMIC I-A, REMIC I-B or REMIC I-C of such REO Property subsequent to three years after its acquisition will not result in the imposition on the any Trust REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder Trust REMIC to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder Trust REMIC of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Master Servicer, on behalf of REMIC 1the Trust Fund and consistent with the servicing standard set forth in Section 3.01, shall either sell any REO Property as soon as practicable and in any event no later than before the end close of the third full taxable year after following the taxable year in which such REMIC the Trust Fund acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such the three-year grace period, unless the Master Servicer shall have delivered to the Trustee Trustee, the Trust Administrator and the Depositor an Opinion of Counsel, addressed to the Trustee Trustee, the Trust Administrator and the Depositor, to the effect that the holding by the REMIC Trust Fund of such REO Property subsequent to three years after its acquisition will not result in the imposition on the any Trust REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder Trust REMIC to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall shall, consistent with the servicing standard set forth in Section 3.01, manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder Trust REMIC of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject related to applicable laws, a Mortgage Loan shall be taken in the name of the Trustee, or its nominee, in trust on behalf of the Trust Fund and for the benefit of the Certificateholders. The related Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than by the end close of the third full taxable calendar year after following the taxable calendar year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8860(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, expire an extension of such the three-year grace period, unless the related Servicer shall have had delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three years after its acquisition will not result in the imposition on the any Trust REMIC created hereunder of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created Trust REMIC hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The related Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs Trust REMIC created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Master Servicer, on behalf of REMIC 1the Trust Fund and consistent with the servicing standard set forth in Section 3.01, shall either sell any REO Property as soon as practicable and in any event no later than before the end close of the third full taxable year after following the taxable year in which such REMIC the Trust Fund acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-three- year grace period would otherwise expire, an extension of such the three-year grace period, unless the Master Servicer shall have delivered to the Trustee and the Depositor an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC Trust Fund of such REO Property subsequent to three years after its acquisition will not result in the imposition on the any Trust REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder Trust REMIC to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall shall, consistent with the servicing standard set forth in Section 3.01, manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder Trust REMIC of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1the Trust Fund (and on behalf of the Trustee for the benefit of the Certificateholders), shall either sell any REO Property as soon as practicable and in any event no later than before the end close of the third full taxable year after the taxable year in which such REMIC the Trust Fund acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such the three-year grace period, unless the Servicer shall have delivered to the Trustee and the Depositor an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC Trust Fund of such REO Property subsequent to three years after its acquisition will not result in the imposition on the any REMIC created hereunder of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs REMIC created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs REMIC created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders, subject to applicable laws. The Servicer, on behalf of REMIC 1the Trust Fund (and on behalf of the Trustee for the benefit of the Certificateholders), shall either sell any REO Property as soon as practicable and in any event no later than before the end close of the third full taxable year after the taxable year in which such REMIC the Trust Fund acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request receive from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such the three-year grace period, unless the Servicer shall have delivered to the Trustee Trustee, the Trust Administrator and the Depositor an Opinion of Counsel, addressed to the Trustee Trustee, the Trust Administrator and the Depositor, to the effect that the holding by the REMIC Trust Fund of such REO Property subsequent to three years after its acquisition will not result in the imposition on the any REMIC created hereunder of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs REMIC created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs REMIC created hereunder of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust on behalf of the Trust Fund and for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than by the end close of the third full taxable calendar year after following the taxable calendar year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8860(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, expire an extension of such the three-year grace period, unless the Servicer shall have delivered to the Trustee Trustee, the Certificate Insurer and the Trust Administrator an Opinion of Counsel, addressed to the Trustee Trustee, the Trust Administrator, the Certificate Insurer and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three years after its acquisition will not result in the imposition on the any Trust REMIC created hereunder of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created Trust REMIC hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs Trust REMIC created hereunder of any "income from non-non- permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject related to applicable laws, a Mortgage Loan shall be taken in the name of the Trustee, or its nominee, in trust on behalf of the Trust Fund and for the benefit of the Certificateholders. The related Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than by the end close of the third full taxable calendar year after following the taxable calendar year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8860(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 sixty (60) days before the day on which the three-year grace period would otherwise expire, expire an extension of such the three-year grace period, unless the related Servicer shall have had delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three (3) years after its acquisition will not result in the imposition on the any Trust REMIC created hereunder of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created Trust REMIC hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The related Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs Trust REMIC created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1, shall sell any REO Property as soon as practicable and in any event no later than the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Servicer shall have delivered to the Trustee and the NIMS Insurer an Opinion of Counsel, Counsel acceptable to the NIMS Insurer and addressed to the Trustee Trustee, the NIMS Insurer and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject related to applicable laws, a Mortgage Loan shall be taken in the name of the Trustee, or its nominee, in trust on behalf of the Trust Fund and for the benefit of the CertificateholdersCertificateholders and the Insurer. The related Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than by the end close of the third full taxable calendar year after following the taxable calendar year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8860(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 sixty (60) days before the day on which the three-year grace period would otherwise expire, expire an extension of such the three-year grace period, unless the related Servicer shall have had delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three (3) years after its acquisition will not result in the imposition on the any Trust REMIC created hereunder of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs created Trust REMIC hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Each Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders and the Insurer solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs Trust REMIC created hereunder of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the CertificateholdersCertificateholders and the Certificate Insurer. The Master Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than the end of the third full taxable year within three years after the taxable year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such the three-year grace period, unless the Master Servicer shall have delivered to the Trust Administrator and the Trustee an Opinion of Counsel, addressed to the Trustee Trust Administrator, the Trustee, the Certificate Insurer and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC I, REMIC II or REMIC III of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder REMIC I, REMIC II or REMIC III to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder REMIC I, REMIC II or REMIC III of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1the Trust Fund and consistent with the servicing standard set forth in Section 3.01, shall either sell any REO Property as soon as practicable and in any event no later than before the end close of the third full taxable year after following the taxable year in which such REMIC the Trust Fund acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-three- year grace period would otherwise expire, an extension of such the three-year grace period, unless the Servicer shall have delivered to the Trustee Trustee, the Trust Administrator and the Depositor an Opinion of Counsel, addressed to the Trustee Trustee, the Trust Administrator and the Depositor, to the effect that the holding by the REMIC Trust Fund of such REO Property subsequent to three years after its acquisition will not result in the imposition on the any Trust REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder Trust REMIC to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall shall, consistent 84 with the servicing standard set forth in Section 3.01, manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder Trust REMIC of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust on behalf of the Trust Fund and for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1the Lower Tier REMIC, shall either sell any REO Property as soon as practicable and in any event no later than by the end close of the third full taxable calendar year after following the taxable calendar year in which such the Lower Tier REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, expire an extension of such the three-year grace period, unless the Servicer shall have had delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the Lower Tier REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the either Trust REMIC created hereunder of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created either Trust REMIC hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs either Trust REMIC created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Master Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than prior to the end of the third full taxable year after the taxable year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such the three-year grace period, unless the Master Servicer shall have delivered to the Trustee and the NIMS Insurer an Opinion of Counsel, Counsel acceptable to the NIMS Insurer and addressed to the Trustee Trustee, the NIMS Insurer and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three years after its acquisition will not result in the imposition on the any Trust REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder Trust REMIC to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder Trust REMIC of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the CertificateholdersCertificateholders and the Certificate Insurer. The Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than the end of the third full taxable year within three years after the taxable year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such the three-year grace period, unless the Servicer shall have delivered to the Trust Administrator and the Trustee an Opinion of Counsel, addressed to the Trustee Trust Administrator, the Trustee, the Certificate Insurer and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC I, REMIC II or REMIC III of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder REMIC I, REMIC II or REMIC III to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder REMIC I, REMIC II or REMIC III of any "income from non-non- permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject related to applicable laws, a Mortgage Loan shall be taken in the name of the Trustee, or its nominee, in trust on behalf of the Trust Fund and for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than by the end close of the third full taxable calendar year after following the taxable calendar year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8860(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, expire an extension of such the three-year grace period, unless the Servicer shall have had delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three years after its acquisition will not result in the imposition on the any Trust REMIC created hereunder of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created Trust REMIC hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs Trust REMIC created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject related to applicable laws, a Mortgage Loan shall be taken in the name of the Trustee, or its nominee, in trust on behalf of the Trust Fund and for the benefit of the Certificateholders. The related Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than by the end close of the third full taxable calendar year after following the taxable calendar year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8860(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 sixty (60) days before the day on which the three-year grace period would otherwise expire, an extension of such the three-year grace period, unless the related Servicer shall have had delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three (3) years after its acquisition will not result in the imposition on the any Trust REMIC created hereunder of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs created Trust REMIC hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Each Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs Trust REMIC created hereunder of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject related to applicable laws, a Mortgage Loan shall be taken in the name of the Trustee, or its nominee, in trust on behalf of the Trust Fund and for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than by the end close of the third full taxable calendar year after following the taxable calendar year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8860(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 sixty (60) days before the day on which the three-year grace period would otherwise expire, an extension of such the three-year grace period, unless the Servicer shall have had delivered to the Trustee and the Class A Certificate Insurer an Opinion of Counsel, addressed to the Trustee Trustee, the Class A Certificate Insurer and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three (3) years after its acquisition will not result in the imposition on the any Trust REMIC created hereunder of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs created Trust REMIC hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs Trust REMIC created hereunder of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the CertificateholdersCertificateholders and the Certificate Insurer. The Master Servicer, on behalf of REMIC 1the Trust Fund, shall either sell any REO Property as soon as practicable and in any event no later than before the end close of the third full taxable year after following the taxable year in which such REMIC the Trust Fund acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the above three-year grace period would otherwise expire, an extension of such the above three-year grace period, unless the Master Servicer shall have delivered to the Trustee Trustee, the Trust Administrator and the Depositor an Opinion of Counsel, addressed to the Trustee Certificate Insurer, the Trustee, the Trust Administrator and the Depositor, to the effect that the holding by the REMIC Trust Fund of such REO Property subsequent to three years the close of the third taxable year after its acquisition will not result in the imposition on the REMIC Trust Fund of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder Trust REMIC to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder Trust REMIC of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1, shall sell any REO Property as soon as practicable and in any event no later than the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the 105 Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Servicer shall have delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Master Servicer, on behalf of REMIC 1the Trust Fund and consistent with the servicing standard set forth in Section 3.01, shall either sell any REO Property as soon as practicable and in any event no later than before the end close of the third full taxable year after following the taxable year in which such REMIC the Trust Fund acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-three- year grace period would otherwise expire, an extension of such the three-year grace period, unless the Master Servicer shall have delivered to the Trustee Trustee, the Trust Administrator and the Depositor an Opinion of Counsel, addressed to the Trustee Trustee, the Trust Administrator and the Depositor, to the effect that the holding by the REMIC Trust Fund of such REO Property subsequent to three years after its acquisition will not result in the imposition on the any Trust REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder Trust REMIC to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall shall, consistent with the servicing standard set forth in Section 3.01, manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder Trust REMIC of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust on behalf of the Trust Fund and for the benefit of the Certificateholders. The related Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than by the end close of the third full taxable calendar year after following the taxable calendar year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, expire an extension of such the three-year grace period, unless the related Servicer shall have had delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three years after its acquisition will not result in the imposition on the any Trust REMIC created hereunder of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created Trust REMIC hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Each Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs Trust REMIC created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1I, shall sell any REO Property as soon as practicable practical and in any event no later than the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Servicer shall have delivered to the Trustee and the NIMS Insurer an Opinion of Counsel, Counsel acceptable to the NIMS Insurer and addressed to the Trustee Trustee, the NIMS Insurer and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Master Servicer, on behalf of REMIC 1the Trust Fund and consistent with the servicing standard set forth in Section 3.01, shall either sell any REO Property as soon as practicable and in any event no later than before the end close of the third full taxable year after following the taxable year in which such REMIC the Trust Fund acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-three- year grace period would otherwise expire, an extension of such the three-year grace period, unless the Master Servicer shall have delivered to the Trustee Trustee, the Trust Administrator and the Depositor an Opinion of Counsel, addressed to the Trustee Trustee, the Trust Administrator and the Depositor, to the effect that the holding by the REMIC Trust Fund of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC I of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder REMIC I to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall shall, consistent with the servicing standard set forth in Section 3.01, manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder REMIC I of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The ServicerGMACM, on behalf of REMIC 1, shall sell any REO Property as soon as practicable and in any event no later than the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Servicer GMACM shall have delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer GMACM shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Master Servicer, on behalf of REMIC 1, shall either sell any REO Property as soon as practicable and in any event no later than by the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Master Servicer shall have delivered to the Trustee an Opinion of Counsel, addressed to the Trustee Trustee, the Certificate Insurer and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or Cor result in the receipt by any of the REMICs created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1the Trust Fund, shall either sell any REO Property as soon as practicable and in any event no later than before the end close of the third full taxable year after following the taxable year in which such REMIC the Trust Fund acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the above three-year grace period would otherwise expire, an extension of such the above three-year grace period, unless the Servicer shall have delivered to the Trustee Trustee, the NIMS Insurer and the Depositor an Opinion of Counsel, addressed to the Trustee Trustee, the NIMS Insurer and the Depositor, to the effect that the holding by the REMIC Trust Fund of such REO Property subsequent to three years the close of the third taxable year after its acquisition will not result in the imposition on the REMIC Trust Fund of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder Trust REMIC to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder Trust REMIC of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the CertificateholdersCertificateholders and the Certificate Insurer. The Master Servicer, on behalf of REMIC 1the REMIC, shall either sell any REO Property as soon as practicable and in any event no later than by the end of the third full taxable year after the taxable year in which such the REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Master Servicer shall have delivered to the Trustee an Opinion of Counsel, addressed to the Trustee Trustee, the Certificate Insurer and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder REMIC to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder REMIC of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Master Servicer, on behalf of REMIC 1the Trust Fund and consistent with the servicing standard set forth in Section 3.01, shall either sell any REO Property as soon as practicable and in any event no later than before the end close of the third full taxable year after following the taxable year in which such REMIC the Trust Fund acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-three- year grace period would otherwise expire, an extension of such the three-year grace period, unless the Master Servicer shall have delivered to the Trustee and the Depositor an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC Trust Fund of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC I or REMIC II of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder REMIC I or REMIC II to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall shall, consistent with the servicing standard set forth in Section 3.01, manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder REMIC I or REMIC II of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.. 91

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the CertificateholdersCertificateholders and the Certificate Insurer. The Master Servicer, on behalf of REMIC 1, shall either sell any REO Property as soon as practicable and in any event no later than by the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Master Servicer shall have delivered to the Trustee an Opinion of Counsel, addressed to the Trustee Trustee, the Certificate Insurer and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to REMIC 1, REMIC 2 or REMIC 3to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder REMIC 1, REMIC 2 or REMIC 3 of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject related to applicable laws, a Ocwen Mortgage Loan shall be taken in the name of the Trustee, or its nominee, in trust on behalf of the Trust Fund and for the benefit of the Certificateholders. The ServicerOcwen, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than by the end close of the third full taxable calendar year after following the taxable calendar year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8860(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, expire an extension of such the three-year grace period, unless the Servicer shall have Ocwen had delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three years after its acquisition will not result in the imposition on the any Trust REMIC created hereunder of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created Trust REMIC hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer Ocwen shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs Trust REMIC created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Master Servicer, on behalf of REMIC 1the Trust Fund and consistent with the servicing standard set forth in Section 3.01, shall either sell any REO Property as soon as practicable and in any event no later than before the end close of the third full taxable year after following the taxable year in which such REMIC the Trust Fund acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such the three-year grace period, unless the Master Servicer shall have delivered to the Trustee and the Depositor an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC Trust Fund of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC I of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder REMIC I to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall shall, consistent with the servicing standard set forth in Section 3.01, manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder REMIC I of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the CertificateholdersCertificateholders and the Certificate Insurer. The Master Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than by the end of the third full taxable year after the taxable year in which such the REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Master Servicer shall have delivered to the Trustee an Opinion of Counsel, addressed to the Trustee Trustee, the Certificate Insurer and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three years the close of the third taxable year after its acquisition will not result in the imposition on the any REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder REMIC to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder REMIC of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust on behalf of the Trust Fund and for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than by the end close of the third full taxable calendar year after following the taxable calendar year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8860(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, expire an extension of such the three-year grace period, unless the Servicer shall have delivered to the Trustee and the Trust Administrator an Opinion of Counsel, addressed to the Trustee Trustee, the Trust Administrator and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three years after its acquisition will not result in the imposition on the any Trust REMIC created hereunder of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created Trust REMIC hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs Trust REMIC created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject related to applicable laws, a Litton Mortgage Loan shall be taken in txxxx xn the name of the Trustee, or its nominee, in trust on behalf of the Trust Fund and for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than by the end close of the third full taxable calendar year after following the taxable calendar year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8860(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, expire an extension of such the three-year grace period, unless the Servicer shall have had delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three years after its acquisition will not result in the imposition on the any Trust REMIC created hereunder of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created Trust REMIC hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs Trust REMIC created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1I, shall sell any REO Property as soon as practicable and in any event no later than the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Servicer shall have delivered to the Trustee and the NIMS Insurer an Opinion of Counsel, Counsel acceptable to the NIMS Insurer and addressed to the Trustee Trustee, the NIMS Insurer and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject related to applicable laws, a Mortgage Loan shall be taken in the name of the Trustee, or its nominee, in trust on behalf of the Trust Fund and for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than by the end close of the third full taxable calendar year after following the taxable calendar year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8860(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 sixty (60) days before the day on which the three-year grace period would otherwise expire, an extension of such the three-year grace period, unless the Servicer shall have had delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three (3) years after its acquisition will not result in the imposition on the any Trust REMIC created hereunder of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs created Trust REMIC hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs Trust REMIC created hereunder of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.. 125

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Master Servicer, on behalf of REMIC 1the Trust Fund, shall either sell any REO Property as soon as practicable and in any event no later than before the end close of the third full taxable year after following the taxable year in which such REMIC the Trust Fund acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the above three-year grace period would otherwise expire, an extension of such the above three-year grace period, unless the Master Servicer shall have delivered to the Trustee Trustee, the Trust Administrator and the Depositor an Opinion of Counsel, addressed to the Trustee Trustee, the Trust Administrator and the Depositor, to the effect that the holding by the REMIC Trust Fund of such REO Property subsequent to three years the close of the third taxable year after its acquisition will not result in the imposition on the REMIC I of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder REMIC I to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder REMIC I of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1, shall sell any REO Property as soon as practicable and in any event no later than the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Servicer shall have delivered to the Trustee and the NIMS Insurer an Opinion of Counsel, addressed to the Trustee Trustee, the NIMS Insurer and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the CertificateholdersCertificateholders and the Certificate Insurer. The Master Servicer, on behalf of REMIC 1the Trust Fund, shall either sell any REO Property as soon as practicable and in any event no later than the end of the third full taxable year within two years after the taxable year in which such REMIC Trust Fund acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the threetwo-year grace period would otherwise expire, an extension of such threethe two-year grace period, unless the Master Servicer shall have delivered to the Trustee Trustee, the Depositor and the Certificate Insurer an Opinion of Counsel, addressed to the Trustee Trustee, the Depositor and the DepositorCertificate Insurer, to the effect that the holding by the REMIC Trust Fund of such REO Property subsequent to three two years after its acquisition will not result in the imposition on the REMIC I or REMIC II of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder REMIC I or REMIC II to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders and the Certificate Insurer solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder REMIC I or REMIC II of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject related to applicable laws, a Mortgage Loan shall be taken in the name of the Trustee, or its nominee, in trust on behalf of the Trust Fund and for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than by the end close of the third full taxable calendar year after following the taxable calendar year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8860(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 sixty (60) days before the day on which the three-year grace period would otherwise expire, expire an extension of such the three-year grace period, unless the Servicer shall have had delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three (3) years after its acquisition will not result in the imposition on the any Trust REMIC created hereunder of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs created Trust REMIC hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs Trust REMIC created hereunder of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.. 125

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1I, shall sell any REO Property as soon as practicable and in any event no later than the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Servicer shall have delivered to the Trustee and the NIMS Insurer an Opinion of Counsel, Counsel acceptable to the NIMS Insurer and addressed to the Trustee Trustee, the NIMS Insurer and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1, shall sell any REO Property as soon as practicable and in any event no later than the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Servicer shall have delivered to the Trustee an Opinion of Counsel, addressed to the Trustee Trustee, the Depositor and the DepositorCertificate Insurer, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject related to applicable laws, a Mortgage Loan shall be taken in the name of the Trustee, or its nominee, in trust on behalf of the Trust Fund and for the benefit of the Certificateholders. The related Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than by the end close of the third full taxable calendar year after following the taxable calendar year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8860(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 sixty (60) days before the day on which the three-year grace period would otherwise expire, expire an extension of such the three-year grace period, unless the such Servicer shall have had delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three (3) years after its acquisition will not result in the imposition on the any Trust REMIC created hereunder of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs created Trust REMIC hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The related Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs Trust REMIC created hereunder of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.. 134

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject related to applicable laws, an Ocwen Mortgage Loan shall be taken in the name of the Trustee, or its nominee, in trust on behalf of the Trust Fund and for the benefit of the Certificateholders. The ServicerOcwen, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than by the end close of the third full taxable calendar year after following the taxable calendar year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8860(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, expire an extension of such the three-year grace period, unless the Servicer shall have Ocwen had delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three years after its acquisition will not result in the imposition on the any Trust REMIC created hereunder of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created Trust REMIC hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer Ocwen shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs Trust REMIC created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject related to applicable laws, a Mortgage Loan shall be taken in the name of the Trustee, or its nominee, in trust on behalf of the Trust Fund and for the benefit of the Certificateholders. The Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than by the end close of the third full taxable calendar year after following the taxable calendar year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8860(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, expire an extension of such the three-year grace period, unless the Servicer shall have had delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three years after its acquisition will not result in the imposition on the any Trust REMIC created hereunder of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs created Trust REMIC hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs Trust REMIC created hereunder of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Master Servicer, on behalf of REMIC 1, shall sell any REO Property as soon as practicable and in any event no later than the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Master Servicer shall have delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit of the Certificateholders. The Master Servicer, on behalf of REMIC 1, shall sell any REO Property as soon as practicable practical and in any event no later than the end of the third full taxable year after the taxable year in which such REMIC acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such three-year period, unless the Master Servicer shall have delivered to the Trustee and the NIMS Insurer an Opinion of Counsel, Counsel acceptable to the NIMS Insurer and addressed to the Trustee Trustee, the NIMS Insurer and the Depositor, to the effect that the holding by the REMIC of such REO Property subsequent to three years after its acquisition will not result in the imposition on the REMIC of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Master Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.permitted

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust on behalf of the Trust Fund and for the benefit of the Certificateholders. The Applicable Servicer, on behalf of REMIC 1I, shall either sell any REO Property as soon as practicable and in any event no later than prior to the end of the third full taxable year after the taxable year in which such REMIC I acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later than 60 days before the day on which the three-year grace period would otherwise expire, an extension of such the three-year grace period, unless the Applicable Servicer shall have delivered to the Trustee and the Securities Administrator an Opinion of Counsel, addressed to the Trustee Trustee, the Securities Administrator and the Depositor, to the effect that the holding by the REMIC I of such REO Property subsequent to three years after its acquisition will not result in the imposition on the any Trust REMIC of taxes on "“prohibited transactions" ” thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder Trust REMIC to fail to qualify as a REMIC under Federal law at any time that any Certificates are outstanding. The Applicable Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "“foreclosure property" ” within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder Trust REMIC of any "“income from non-permitted assets" ” within the meaning of Section 860F(a)(2)(B) of the Code, or any "“net income from foreclosure property" ” which is subject to taxation under the REMIC Provisions.

Title, Management and Disposition of REO Property. (a) The deed or certificate of sale of any REO Property shall, subject to applicable laws, shall be taken in the name of the Trustee, or its nominee, in trust for the benefit on behalf of the Certificateholders. The Master Servicer, on behalf of REMIC 1the Trust Fund, shall either sell any REO Property as soon as practicable and in any event no later than before the end close of the third full taxable year after following the taxable year in which such REMIC the Trust Fund acquires ownership of such REO Property for purposes of Section 860G(a)(8) of the Code or request from the Internal Revenue Service, no later more than 60 days before the day on which the three-year grace period would otherwise expire, expire an extension of such three-year the grace period, unless the Master Servicer shall have delivered to the Trustee an Opinion of Counsel, addressed to the Trustee and the DepositorCompany, which Opinion of Counsel shall not be at the expense of the Trust 66 Fund or the Trustee, to the effect that the holding by the REMIC I of such REO Property subsequent to three years such period after its acquisition will not result in the imposition on the REMIC I, REMIC II or REMIC III of taxes on "prohibited transactions" thereof, as defined in Section 860F of the Code, or cause any of the REMICs created hereunder REMIC I, REMIC II or REMIC III to fail to qualify as a REMIC under Federal federal tax law at any time that any Certificates are outstanding. The Master Servicer shall manage, conserve, protect and operate each REO Property for the Certificateholders solely for the purpose of its prompt disposition and sale in a manner which does not cause such REO Property to fail to qualify as "foreclosure property" within the meaning of Section 860G(a)(8) of the Code or result in the receipt by any of the REMICs created hereunder REMIC I, REMIC II or REMIC III of any "income from non-permitted assets" within the meaning of Section 860F(a)(2)(B) of the Code, or any "net income from foreclosure property" which is subject to taxation under the REMIC Provisions.