Common use of Accounting and Records Clause in Contracts

Accounting and Records. to the Noteholders, Certificateholders, the Internal Revenue Service and Others. Subject to Sections 8.01(b)(iii) and 8.01(c) of the Sale and Servicing Agreement, the Sponsor shall (a) maintain (or cause to be maintained) the books of the Trust on a calendar year basis on the accrual method of accounting, including, without limitation, the allocations of net income under Section 2.11 hereof, (b) deliver (or cause to be delivered) to each Certificateholder, as may be required by the Code and applicable Treasury Regulations, such information as may be required (including Schedule K-1, if applicable) to enable each Certificateholder to prepare its Federal and state income tax returns, (c) file or cause to be filed, if necessary, such tax returns relating to the Trust (including a partnership information return, Form 1065), and direct the Owner Trustee or the Servicer, as the case may be, to make such elections as may from time to time be required or appropriate under any applicable state or Federal statute or rule or regulation thereunder so as to maintain the Trust's characterization as a branch, or if applicable, as a partnership, for Federal income tax purposes and (d) collect or cause to be collected any withholding tax as described in and in accordance with Section 8.01(b)(ii) of the Sale and Servicing Agreement with respect to income or distributions to Certificateholders and the appropriate forms relating thereto. The Owner Trustee or the Servicer, as the case may be, shall make all elections pursuant to this Section as directed in writing by the Sponsor. The Owner Trustee shall sign all tax information returns, if any, filed pursuant to this Section 5.1 and any other returns as may be required by law, and in doing so shall rely entirely upon, and shall have no liability for information provided by, or calculations provided by, the Sponsor or the Servicer. The Sponsor will direct the Owner Trustee and the Owner Trustee shall elect under Section 1278 of the Code to include in income currently any market discount that accrues with respect to the Mortgage Loans. The Sponsor shall not direct the Owner Trustee and the Owner Trustee shall not make the election provided under Section 754 of the Code.

Accounting and Records. to the Noteholders, Residual Certificateholders, the Internal Revenue Service and Others. Subject to Sections 8.01(b)(iii) and 8.01(c) of the Sale and Servicing Agreement, the Sponsor shall (a) maintain (or cause to be maintained) the books of the Trust on a calendar year basis on the accrual method of accounting, including, without limitation, the allocations of net income under Section 2.11 hereof, (b) deliver (or cause to be delivered) to each Residual Certificateholder, as may be required by the Code and applicable Treasury Regulations, such information as may be required (including Schedule K-1, if applicable) to enable each Residual Certificateholder to prepare its Federal and state income tax returns, (c) file or cause to be filed, if necessary, such tax returns relating to the Trust (including a partnership information return, Form 1065), and direct the Owner Trustee or the Servicer, as the case may be, to make such elections as may from time to time be required or appropriate under any applicable state or Federal statute or rule or regulation thereunder so as to maintain the Trust's characterization as a branch, or if applicable, as a partnership, for Federal income tax purposes and (d) collect or cause to be collected any withholding tax as described in and in accordance with Section 8.01(b)(ii) of the Sale and Servicing Agreement with respect to income or distributions to Residual Certificateholders and the appropriate forms relating thereto. The Owner Trustee or the Servicer, as the case may be, shall make all elections pursuant to this Section as directed in writing by the Sponsor. The Owner Trustee shall sign all tax information returns, if any, filed pursuant to this Section 5.1 6.1 and any other returns as may be required by law, and in doing so shall rely entirely upon, and shall have no liability for information provided by, or calculations provided by, the Sponsor or the Servicer. The Sponsor will direct the Owner Trustee and the Owner Trustee shall elect under Section 1278 of the Code to include in income currently any market discount that accrues with respect to the Mortgage Loans. The Sponsor shall not direct the Owner Trustee to make, and the Owner Trustee shall not make make, the election provided under Section 754 of the Code.

Accounting and Records. to the Noteholders, Certificateholders, the Internal Revenue Service and Others. Subject to Sections 8.01(b)(iii12.1(b)(iii) and 8.01(c12.1(c) of the Sale and Servicing Agreement, the Sponsor Depositor shall (a) maintain (or cause to be maintained) the books of the Trust on a calendar year basis on the accrual method of accounting, including, without limitation, the allocations of net income under Section 2.11 hereof2.11, (b) deliver (or cause to be delivered) to each Certificateholder, as may be required by the Code and applicable Treasury Regulations, such information as may be required (including Schedule K-1, if applicable) to enable each Certificateholder to prepare its Federal and state income tax returns, (c) file or cause to be filed, if necessary, such tax returns relating to the Trust (including a partnership information return, Form 1065), and direct the Owner Trustee or the Servicer, as the case may be, to make such elections as may from time to time be required or appropriate under any applicable state or Federal statute or rule or regulation thereunder so as to maintain the Trust's characterization as a branch, or if applicable, as a partnership, for Federal income tax purposes and (d) collect or cause to be collected any withholding tax as described in and in accordance with Section 8.01(b)(ii5.9(c) of the Sale and Servicing Serving Agreement with respect to income or distributions to Certificateholders and the appropriate forms relating thereto. The Owner Trustee or the Servicer, as the case may be, shall make all elections pursuant to this Section as directed in writing by the SponsorDepositor. The Owner Trustee shall sign all tax information returns, if any, filed pursuant to this Section 5.1 and any other returns as may be required by law, and in doing so shall rely entirely upon, and shall have no liability for information provided by, or calculations provided by, the Sponsor Depositor or the Servicer. The Sponsor will direct the Owner Trustee and the Owner Trustee shall elect under Section 1278 of the Code to include in income currently any market discount that accrues with respect to the Mortgage LoansReceivables. The Sponsor shall not direct the Owner Trustee and the Owner Trustee shall not make the election provided under Section 754 of the Code.

Accounting and Records. to the Noteholders, Certificateholders, the Internal Revenue Service and Others. Subject to Sections 8.01(b)(iii12.1(b)(iii) and 8.01(c12.1(c) of the Sale and Servicing Agreement, the Sponsor Depositor shall (a) maintain (or cause to be maintained) the books of the Trust on a calendar year basis on the accrual method of accounting, including, without limitation, the allocations of net income under Section 2.11 hereofss. 2.11, (b) deliver (or cause to be delivered) to each Certificateholder, as may be required by the Code and applicable Treasury Regulations, such information as may be required (including Schedule K-1, if applicable) to enable each Certificateholder to prepare its Federal and state income tax returns, (c) file or cause to be filed, if necessary, such tax returns relating to the Trust (including a partnership information return, Form 1065), and direct the Owner Trustee or the Master Servicer, as the case may be, to make such elections as may from time to time be required or appropriate under any applicable state or Federal statute or rule or regulation thereunder so as to maintain the Trust's characterization as a branch, or if applicable, as a partnership, for Federal income tax purposes and (d) collect or cause to be collected any withholding tax as described in and in accordance with Section 8.01(b)(iiss. 5.9(c) of the Sale and Servicing Serving Agreement with respect to income or distributions to Certificateholders and the appropriate forms relating thereto. The Owner Trustee or the Master Servicer, as the case may be, shall make all elections pursuant to this Section ss. as directed in writing by the SponsorDepositor. The Owner Trustee shall sign all tax information returns, if any, filed pursuant to this Section ss. 5.1 and any other returns as may be required by law, and in doing so shall rely entirely upon, and shall have no liability for information provided by, or calculations provided by, the Sponsor Depositor or the Master Servicer. The Sponsor will direct the Owner Trustee and the Owner Trustee shall elect under Section ss. 1278 of the Code to include in income currently any market discount that accrues with respect to the Mortgage LoansReceivables. The Sponsor shall not direct the Owner Trustee and the Owner Trustee shall not make the election provided under Section ss. 754 of the Code.

Accounting and Records. to the Class C Noteholders, Certificateholders, the Internal Revenue Service and Others. Subject to Sections 8.01(b)(iii) and 8.01(c) of the Sale and Servicing Agreement, the The Sponsor shall (a) maintain (or cause to be maintained) the books of the Trust C on a calendar year basis on the accrual method of accounting, including, without limitation, the allocations of net income under Section 2.11 hereof, (b) deliver (or cause to be delivered) to each Certificateholder, as may be required by the Code and applicable Treasury Regulations, such information as may be required (including Schedule K-1, if applicable) to enable each Certificateholder to prepare its Federal and state income tax returns, (c) file or cause to be filed, if necessary, such tax returns relating to the Trust C (including a partnership information return, Form 1065), and direct the Owner Trustee or the Master Servicer, as the case may be, to make such elections 15 20 as may from time to time be required or appropriate under any applicable state or Federal statute or rule or regulation thereunder so as to maintain the TrustTrust C's characterization as a branch, or if applicable, as a partnership, for Federal income tax purposes and (d) collect or cause to be collected any withholding tax as described in and in accordance with Section 8.01(b)(ii6.1(a)(ii) of the Trust C Sale and Servicing Agreement with respect to income or distributions to Certificateholders and the appropriate forms relating thereto. The Owner Trustee or the Master Servicer, as the case may be, shall make all elections pursuant to this Section as directed in writing by the Sponsor. The Owner Trustee shall sign all tax information returnsreturns presented to it in final execution form, if any, filed pursuant to this Section 5.1 and any other returns as may be required by law, and in doing so shall rely entirely upon, and shall have no liability for information provided by, or calculations provided by, the Sponsor or the Master Servicer. The Sponsor will direct the Owner Trustee and the Owner Trustee shall elect under Section 1278 of the Code to include in income currently any market discount that accrues with respect to the Mortgage Loans. The Sponsor shall not direct the Owner Trustee and the Owner Trustee shall not make the election provided under Section 754 of the Code.

Accounting and Records. to the Noteholders, Certificateholders, the Internal Revenue Service and Others. Subject to Sections 8.01(b)(iii6.01(b)(iii) and 8.01(c6.01(c) of the Sale and Servicing Agreement, the Sponsor shall (a) maintain (or cause to be maintained) the books of the Trust on a calendar year basis on the accrual method of accounting, including, without limitation, the allocations of net income under Section 2.11 hereof, (b) deliver (or cause to be delivered) to each Certificateholder, as may be required by the Code and applicable Treasury Regulations, such information as may be required (including Schedule K-1, if applicable) to enable each Certificateholder to prepare its Federal and state income tax returns, (c) file or cause to be filed, if necessary, filed such tax returns relating to the Trust (including a partnership information corporate return, Form 10651120), and direct the Owner Trustee or the Master Servicer, as the case may be, to make such elections and file such forms as may from time to time be required or appropriate under any applicable state or Federal statute or rule or regulation thereunder so as to maintain given the Trust's characterization as a branchcorporation, or if applicable, as a partnership, for Federal income tax purposes and (d) collect or cause to be collected any withholding tax as described in and in accordance with Section 8.01(b)(ii6.01(b)(ii) of the Sale and Servicing Agreement with respect to income or distributions to Certificateholders and the appropriate forms relating thereto. The Owner Trustee or the Master Servicer, as the case may be, shall make all elections pursuant to this Section as directed in writing by the Sponsor. The Owner Trustee shall sign all tax information returnsreturns presented to it in final execution form, if any, filed pursuant to this Section 5.1 5.01 and any other returns as may be required by law, and in doing so shall rely entirely upon, and shall have no liability for information provided by, or calculations provided by, the Sponsor or the Master Servicer. The Sponsor will direct the Owner Trustee and the Owner Trustee shall elect under Section 1278 of the Code on behalf of the Trust to include in income currently any market discount that accrues with respect to the Mortgage Loans. The Sponsor shall not direct the Owner Trustee and the Owner Trustee shall not make the election provided under Section 754 of the Code.

Accounting and Records. to the Noteholders, Certificateholders, the Internal Revenue Service and Others. Subject to Sections 8.01(b)(iii12.1(b)(iii) and 8.01(c12.1(c) of the Sale and Servicing Agreement, the Sponsor Depositor shall (a) maintain (or cause to be maintained) the books of the Trust on a calendar year basis on the accrual method of accounting, including, without limitation, including the allocations of net income under Section 2.11 hereofss. 2.11, (b) deliver (or cause to be delivered) to each Certificateholder, as may be required by the Code and applicable Treasury Regulations, such information as may be required (including Schedule K-1, if applicable) to enable each Certificateholder to prepare its Federal and state income tax returns, (c) file or cause to be filed, if necessary, such tax returns relating to the Trust (including a partnership information return, Form 1065, if applicable), and direct the Owner Trustee or the Master Servicer, as the case may be, to make such elections as may from time to time be required or appropriate under any applicable state or Federal statute or rule or regulation thereunder so as to maintain the Trust's characterization as a branch, or if applicable, as a partnership, for Federal income tax purposes and (d) collect or cause to be collected any withholding tax as described in and in accordance with Section 8.01(b)(iiss. 5.9(c) of the Sale and Servicing Serving Agreement with respect to income or distributions to Certificateholders and the appropriate forms relating thereto. The Owner Trustee or the Master Servicer, as the case may be, shall make all elections pursuant to this Section ss. 5.1 as directed in writing by the SponsorDepositor. The Owner Trustee shall sign all tax information returns, if any, filed pursuant to this Section ss. 5.1 and any other returns as may be required by law, and in doing so shall rely entirely upon, and shall have no liability for information provided by, or calculations provided by, the Sponsor Depositor or the Master Servicer. The Sponsor will direct the Owner Trustee and the Owner Trustee shall elect under Section ss. 1278 of the Code to include in income currently any market discount that accrues with respect to the Mortgage LoansReceivables. The Sponsor shall not direct the Owner Trustee and the Owner Trustee shall not make the election provided under Section ss. 754 of the Code.

Accounting and Records. to the Noteholders, Certificateholders, the Internal Revenue Service and Others. Subject to Sections 8.01(b)(iii12.1(b)(iii) and 8.01(c12.1(c) of the Master Sale and Servicing Agreement, the Sponsor Master Servicer shall (a) maintain (or cause to be maintained) the books of the Trust on a calendar year basis on the accrual method of accounting, including, without limitation, the allocations of net income under Section 2.11 hereofss. 2.11, (b) deliver (or cause to be delivered) to each Certificateholder, as may be required by the Code and applicable Treasury Regulations, such information as may be required (including Schedule K-1, if applicable) to enable each Certificateholder to prepare its Federal and state income tax returns, (c) file or cause to be filed, if necessary, such tax returns relating to the Trust (including a partnership information return, Form 1065), and direct the Owner Trustee or the Master Servicer, as the case may be, to make such elections as may from time to time be required or appropriate under any applicable state or Federal statute or rule or regulation thereunder so as to maintain the Trust's characterization as a branch, or if applicable, as a partnership, for Federal income tax purposes and (d) collect or cause to be collected any withholding tax as described in and in accordance with Section 8.01(b)(ii) of the Master Sale and Servicing Serving Agreement or any Series Supplement with respect to income or distributions to Certificateholders and the appropriate forms relating thereto. The Owner Trustee or the Master Servicer, as the case may be, shall make all elections pursuant to this Section ss. 5.1 as directed in writing by the SponsorDepositor. The Owner Trustee shall sign all tax information returns, if any, filed pursuant to this Section ss. 5.1 and any other returns as may be required by law, and in doing so shall rely entirely upon, and shall have no liability for information provided by, or calculations provided by, the Sponsor Depositor or the Master Servicer. The Sponsor will direct the Owner Trustee and the Owner Trustee shall elect under Section ss. 1278 of the Code to include in income currently any market discount that accrues with respect to the Mortgage LoansReceivables. The Sponsor shall not direct the Owner Trustee and the Owner Trustee shall not make the election provided under Section ss. 754 of the Code.

Accounting and Records. to the Class A Noteholders, Certificateholders, the Internal Revenue Service and Others. Subject to Sections 8.01(b)(iii) and 8.01(c) of the Sale and Servicing Agreement, the The Sponsor shall (a) maintain (or cause to be maintained) the books of the Trust A on a calendar year basis on the accrual method of accounting, including, without limitation, the allocations of net income under Section 2.11 hereof, (b) deliver (or cause to be delivered) to each Certificateholder, as may be required by the Code and applicable Treasury Regulations, such information as may be required (including Schedule K-1, if applicable) to enable each Certificateholder to prepare its Federal and state income tax returns, (c) file or cause to be filed, if necessary, such tax returns relating to the Trust A (including a partnership information return, Form 1065), and direct the Owner Trustee or the Master Servicer, as the case may be, to make such elections as may from time to time be required or appropriate under any applicable state or Federal statute or rule or regulation thereunder so as to maintain the TrustTrust A's characterization as a branch, or if applicable, as a partnership, for Federal income tax purposes and (d) collect or cause to be collected any withholding tax as described in and in accordance with Section 8.01(b)(ii6.1(a)(ii) of the Trust A Sale and Servicing Agreement with respect to income or distributions to Certificateholders and the appropriate forms relating thereto. The Owner Trustee or the Master Servicer, as the case may be, shall make all elections pursuant to this Section as directed in writing by the Sponsor. The Owner Trustee shall sign all tax information returnsreturns presented to it in final execution form, if any, filed pursuant to this Section 5.1 and any other returns as may be required by law, and in doing so shall rely entirely upon, and shall have no liability for information provided by, or calculations provided by, the Sponsor or the Master Servicer. The Sponsor will direct the Owner Trustee and the Owner Trustee shall elect under Section 1278 of the Code to include in income currently any market discount that accrues with respect to the Mortgage Loans. The Sponsor shall not direct the Owner Trustee and the Owner Trustee shall not make the election provided under Section 754 of the Code.

Accounting and Records. to the Noteholders, Residual Certificateholders, the Internal Revenue Service and Others. Subject to Sections 8.01(b)(iii) and 8.01(c) of the Sale and Servicing Agreement, the Sponsor The Indenture Trustee shall (a) maintain (or cause to be maintained) the books of the Trust on a calendar year basis on the accrual method of accounting, including, without limitation, the allocations of net income under Section 2.11 hereof, (b) deliver (or cause to be delivered) to each Residual Certificateholder, as may be required by the Code and applicable Treasury Regulations, such information as may be required (including Schedule K-1, if applicable) to enable each Residual Certificateholder to prepare its Federal federal and state income tax returns, (c) prepare, file or cause to be filed, if necessary, such tax returns relating to the Trust (including a partnership information return, Form 1065, if applicable), and direct the Owner Trustee or the ServicerDepositor, as the case may be, to make such elections as may from time to time be required or appropriate under any applicable state or Federal federal statute or rule or regulation thereunder so as to maintain the Trust's characterization as a branch, or if applicable, as a partnership, partnership for Federal federal income tax purposes and (d) collect or cause to be collected any withholding tax as described in and in accordance with Section 8.01(b)(ii) of the Sale and Servicing Agreement with respect to income or distributions to Residual Certificateholders and the appropriate forms relating thereto. The Owner Trustee or the ServicerResidual Certificateholders, as the case may be, shall make all elections pursuant to this Section as directed in writing by the SponsorIndenture Trustee. The Owner Trustee shall sign all tax information returns, if any, prepared and filed pursuant to this Section 5.1 6.1 and any other returns as may be required by law, and in doing so shall rely entirely upon, and shall have no liability for information provided by, or calculations provided by, the Sponsor or the ServicerIndenture Trustee. The Sponsor Indenture Trustee will direct the Owner Trustee and the Owner Trustee shall elect under Section 1278 of the Code to include in income currently any market discount that accrues with respect to the Mortgage Loans. The Sponsor Indenture Trustee shall not direct the Owner Trustee to make, and the Owner Trustee shall not make make, the election provided under Section 754 of the Code.

Accounting and Records. to the Noteholders, Certificateholders, the Internal Revenue Service and Others. Subject to Sections 8.01(b)(iii12.1(b)(iii) and 8.01(c12.1(c) of the Sale and Servicing Agreement, the Sponsor Depositor shall (a) maintain (or cause to be maintained) the books of the Trust on a calendar year basis on the accrual method of accounting, including, without limitation, the allocations of net income under Section 2.11 hereof2.11, (b) deliver (or cause to be delivered) to each Certificateholder, as may be required by the Code and applicable Treasury Regulations, such information as may be required (including Schedule K-1, if applicable) to enable each Certificateholder to prepare its Federal and state income tax returns, (c) file or cause to be filed, if necessary, such tax returns relating to the Trust (including a partnership information return, Form 1065), and direct the Owner Trustee or the Master Servicer, as the case may be, to make such elections as may from time to time be required or appropriate under any applicable state or Federal statute or rule or regulation thereunder so as to maintain the Trust's characterization as a branch, or if applicable, as a partnership, for Federal income tax purposes and (d) collect or cause to be collected any withholding tax as described in and in accordance with Section 8.01(b)(ii5.9(c) of the Sale and Servicing Serving Agreement with respect to income or distributions to Certificateholders and the appropriate forms relating thereto. The Owner Trustee or the Master Servicer, as the case may be, shall make all elections pursuant to this Section as directed in writing by the SponsorDepositor. The Owner Trustee shall sign all tax information returns, if any, filed pursuant to this Section 5.1 and any other returns as may be required by law, and in doing so shall rely entirely upon, and shall have no liability for information provided by, or calculations provided by, the Sponsor Depositor or the Master Servicer. The Sponsor will direct the Owner Trustee and the Owner Trustee shall elect under Section 1278 of the Code to include in income currently any market discount that accrues with respect to the Mortgage LoansReceivables. The Sponsor shall not direct the Owner Trustee and the Owner Trustee shall not make the election provided under Section 754 of the Code.

Accounting and Records. to the Noteholders, CertificateholdersOwners, the Internal Revenue Service and Others. Subject to Sections 8.01(b)(iii) and 8.01(c) of the Sale and Servicing Agreement, the Sponsor The Depositor shall (ai) maintain (or cause to be maintained) the books of the Trust on a calendar year basis on the accrual method of accounting, including, without limitation, the allocations of net income under Section 2.11 hereof5.01, (bii) deliver (or cause to be delivered) to each CertificateholderHolder, as may be required by the Code and applicable Treasury Regulations, such information as may be required (including Schedule K-1, if applicable) to enable each Certificateholder Holder to prepare its Federal and state income tax returns, returns and (ciii) file or cause to be filed, if necessary, such tax returns relating to the Trust (including a partnership information return, Form 1065), and direct the Owner Trustee or the Servicer, as the case may be, to make such elections as may from time to time be required or appropriate under any applicable state or Federal statute or rule or regulation thereunder so as to maintain the Trust's characterization as a branch, or if applicable, as a partnership, for Federal income tax purposes and (d) collect or cause to be collected any withholding tax as described in and in accordance with Section 8.01(b)(ii) of the Sale and Servicing Agreement with respect to income or distributions to Certificateholders and the appropriate forms relating theretopurposes. The Owner Trustee or the Servicer, as the case may be, shall make all elections pursuant to this Section 5.03 as directed in writing by the SponsorDepositor. The Owner Trustee An Authorized Officer of the Trust shall sign all tax information returns, if any, filed pursuant to this Section 5.1 5.03 and any other returns as may be required by law, and in doing so shall rely entirely upon, and shall have no liability for information provided by, or calculations provided by, the Sponsor Depositor or the Servicer. The Sponsor will direct the Owner Trustee and the Owner Trustee Depositor shall elect under Section 1278 of the Code to include in income currently any market discount that accrues with respect to the Mortgage Loans. The Sponsor shall not direct the Owner Trustee and the Owner Trustee Depositor shall not make the election provided under Section 754 of the Code.

Accounting and Records. to the Noteholders, Certificateholders, the Internal Revenue Service and Others. Subject to Sections 8.01(b)(iii5.1(b)(iii) and 8.01(c5.1(c) of the Sale and Servicing Agreement, the Sponsor shall (a) maintain (or cause to be maintained) the books of the Trust on a calendar year basis on the accrual method of accounting, including, without limitation, the allocations of net income under Section 2.11 hereof, (b) deliver (or cause to be delivered) to each Certificateholder, as may be required by the Code and applicable Treasury Regulations, such information as may be required (including Schedule K-1, if applicable) to enable each Certificateholder to prepare its Federal and state income tax returns, (c) file or cause to be filed, if necessary, such tax returns relating to the Trust (including a partnership information return, Form 1065), and direct the Owner Trustee or the Master Servicer, as the case may be, to make such elections as may from time to time be required or appropriate under any applicable state or Federal statute or rule or regulation thereunder so as to maintain the Trust's characterization as a branch, or if applicable, as a partnership, for Federal income tax purposes and (d) collect or cause to be collected any withholding tax as described in and in accordance with Section 8.01(b)(ii5.1(b)(ii) of the Sale and Servicing Agreement with respect to income or distributions to Certificateholders and the appropriate forms relating thereto. The Owner Trustee or the Master Servicer, as the case may be, shall make all elections pursuant to this Section as directed in writing by the Sponsor. The Owner Trustee shall sign all tax information returnsreturns presented to it in final execution form, if any, filed pursuant to this Section 5.1 and any other returns as may be required by law, and in doing so shall rely entirely upon, and shall have no liability for information provided by, or calculations provided by, the Sponsor or the Servicer. The Sponsor will direct the Owner Trustee and the Owner Trustee shall elect under Section 1278 of the Code to include in income currently any market discount that accrues with respect to the Mortgage Loans. The Sponsor shall not direct the Owner Trustee and the Owner Trustee shall not make the election provided under Section 754 of the Code.information

Accounting and Records. to the Noteholders, Class S Certificateholders, Residual Certificateholders, the Internal Revenue Service and Others. Subject to Sections 8.01(b)(iii) and 8.01(c) of the Sale and Servicing Agreement, the Sponsor shall (a) maintain (or cause to be maintained) the books of the Trust on a calendar year basis on the accrual method of accounting, including, without limitation, the allocations of net income under Section 2.11 hereof, (b) deliver (or cause to be delivered) to each Class S Certificateholder and Residual Certificateholder, as may be required by the Code and applicable Treasury Regulations, such information as may be required (including Schedule K-1, if applicable) to enable each Class S Certificateholder and Residual Certificateholder to prepare its Federal and state income tax returns, (c) file or cause to be filed, if necessary, such tax returns relating to the Trust (including a partnership information return, Form 1065), and direct the Owner Trustee or the Servicer, as the case may be, to make such elections as may from time to time be required or appropriate under any applicable state or Federal statute or rule or regulation thereunder so as to maintain the Trust's characterization as a branch, or if applicable, as a partnership, for Federal income tax purposes and (d) collect or cause to be collected any withholding tax as described in and in accordance with Section 8.01(b)(ii) of the Sale and Servicing Agreement with respect to income or distributions to Class S Certificateholders and Residual Certificateholders and the appropriate forms relating thereto. The Owner Trustee or the Servicer, as the case may be, shall make all elections pursuant to this Section as directed in writing by the Sponsor. The Owner Trustee shall sign all tax information returns, if any, filed pursuant to this Section 5.1 6.1 and any other returns as may be required by law, and in doing so shall rely entirely upon, and shall have no liability for information provided by, or calculations provided by, the Sponsor or the Servicer. The Sponsor will direct the Owner Trustee and the Owner Trustee shall elect under Section 1278 of the Code to include in income currently any market discount that accrues with respect to the Mortgage Loans. The Sponsor shall not direct the Owner Trustee to make, and the Owner Trustee shall not make make, the election provided under Section 754 of the Code.