Common use of Creation of the Grantor Trust Clause in Contracts

Creation of the Grantor Trust. The parties hereto will treat the Grantor Trust as a grantor trust for federal income tax purposes, and the Class ELP Certificates as representing undivided beneficial interests in the Grantor Trust consisting of the Excess Liquidation Proceeds Option. As provided herein, the Certificate Administrator shall take all actions expressly required hereunder to ensure that the portion of the Trust Fund consisting of the Grantor Trust maintains its status as a grantor trust under federal income tax law and not be treated as part of the Trust REMICs.