Common use of Federal Information Returns and Reports to Certificateholders Clause in Contracts

Federal Information Returns and Reports to Certificateholders. (a) For Federal income tax purposes, the taxable year of the REMIC Trust shall be a calendar year and the Trustee shall maintain or cause the maintenance of the books of the REMIC Trust assets on the accrual method of accounting. (b) The Trustee shall prepare and file or cause to be filed with the Internal Revenue Service Federal tax information returns with respect to the REMIC Trust, the Trust Fund, if applicable, and the Certificates containing such information and at the times and in the manner as may be required by the Code or applicable Treasury regulations, and shall furnish to each Holder of Certificates at any time during the calendar year for which such returns or reports are made such statements or information at the times and in the manner as may be required thereby. In connection with the foregoing, the Trustee shall provide the name and address of the person who can be contacted to obtain information required to be reported to the holders of regular interests in the REMIC Trust (the "REMIC Reporting Agent") as required by IRS Form 8811. The Trustee shall make the elections to treat the REMIC Trust as a REMIC (which election shall apply to the taxable period ending December 31, 1997 and each calendar year thereafter) in such manner as the Code or applicable Treasury regulations may prescribe. The Trustee shall sign all tax information returns filed pursuant to this Section and any other returns as may be required by the Code, and in doing so shall rely entirely upon, and shall have no liability for information or calculations contained in the Pooled Certificate Distribution Date Statements. The Trustee is hereby designated as the "Tax Matters Person" (within the meaning of Treas. Reg. ' 1.860F-4(d)) for the REMIC Trust. Any Holder of a Residual Certificate will by acceptance thereof appoint the Trustee as agent and attorney-in-fact for the purpose of acting as Tax Matters Person for the REMIC Trust during such time as the Trustee does not own any such Residual Certificate. In the event that the Code or applicable Treasury regulations prohibit the Trustee from signing tax or information returns or other statements, or the Trustee from acting as Tax Matters Person (as an agent or otherwise), the Trustee shall take whatever action that in its sole good faith judgment is necessary for the proper filing of such information returns or for the provision of a tax matters person, including designation of the Holder of the Residual Certificate to sign such returns or act as tax matters person. Each Holder of the Residual Certificate shall be bound by this Section. (c) The Trustee shall provide upon request such information as is required in Section 860D(a)(6)(B) of the Code to the Internal Revenue Service, to any Person purporting to transfer a Residual Certificate to a Person other than a transferee permitted by Section 5.05(b), and to any regulated investment company, real estate investment trust, common trust fund, partnership, trust, estate, organization described in Section 1381 of the Code, or nominee holding an interest in a pass-through entity described in Section 860E(e)(6) of the Code, any record holder of which is not a transferee permitted by Section 5.05(b) (or which is deemed by statute to be an entity with a disqualified member). (d) The Trustee shall prepare and file or cause to be filed any state income tax returns required with respect to the REMIC Trust or the Trust Fund.

Federal Information Returns and Reports to Certificateholders. (a) For Federal income tax purposes, the taxable year of for the REMIC Trust shall be a calendar year and the Trustee shall maintain or cause the maintenance of the books of each of the REMIC Trust assets on the accrual method of accounting. (b) The Trustee shall prepare and file or cause to be filed with the Internal Revenue Service Federal federal tax information returns with respect to the REMIC TrustREMIC, the Trust FundTrust, if applicable, and the Certificates containing such information and at the times and in the manner as may be required by the Code or applicable Treasury regulations, and shall furnish to each Holder of Certificates at any time during the calendar year for which such returns or reports are made such statements or information at the times and in the manner as may be required thereby. In connection with the foregoing, the Trustee shall provide the name and address of the person who can be contacted to obtain information required to be reported to the holders of regular interests in the of REMIC Trust (the "REMIC Reporting Agent") as required by IRS Form 8811. The Trustee shall make the elections to treat the of REMIC Trust as a REMIC (which election shall apply to the taxable period ending December 31, 1997 2001 and each calendar year thereafter) in such manner as the Code or applicable Treasury regulations may prescribe. The Trustee shall sign all tax information returns filed pursuant to this Section and any other returns as may be required by the Code, and in doing so shall rely entirely upon, and shall have no liability for information or calculations contained in the Pooled Certificate Security Distribution Date Statements. The Trustee Holder of the Class R Certificate is hereby designated as the "Tax Matters Person" (within the meaning of Treas. Reg. ' 1.860F-4(dss.1.860F-4(d)) for the REMIC TrustREMIC. The Trustee is hereby designated and appointed as the agent of such Tax Matters Person. Any Holder of a Residual Class R Certificate will by acceptance thereof appoint the Trustee as agent and attorney-in-fact for the purpose of acting as Tax Matters Person for the REMIC Trust during such time as the Trustee does not own any such Residual the Class R Certificate. In the event that the Code or applicable Treasury regulations prohibit the Trustee from signing tax or information returns or other statements, or the Trustee from acting as Tax Matters Person (as an agent or otherwise), the Trustee shall take whatever action that in its sole good faith judgment is necessary for the proper filing of such information returns or for the provision of a tax matters person, including designation of the Holder of the Residual Class R Certificate to sign such returns or act as tax matters person. Each Holder of the Residual Class R Certificate shall be bound by this Section. (c) The Trustee shall provide upon request such information as is required in Section 860D(a)(6)(B) of the Code to the Internal Revenue Service, to any Person purporting to transfer a Residual Class R Certificate to a Person other than a transferee permitted by Section 5.05(b4.05(b), and to any regulated investment company, real estate investment trust, common trust fund, partnership, trust, estate, organization described in Section 1381 of the Code, or nominee holding an interest in a pass-through entity described in Section 860E(e)(6) of the Code, any record holder of which is not a transferee permitted by Section 5.05(b4.05(b) (or which is deemed by statute to be an entity with a disqualified member). (d) The Trustee shall prepare and file or cause to be filed any state New York State income tax returns required with respect to the REMIC Trust or the Trust Fundand upon receipt of the notice and confirmation required by the terms of Section 3.06(f) to prepare and file or cause to be filed any tax returns required by any other states with respect to the REMIC or the Trust.

Federal Information Returns and Reports to Certificateholders. (a) For Federal income tax purposesThe books of the Trust Fund shall reflect all payments made with respect to the Mortgage Loans, and amounts attributable to the Class A Certificateholders, the taxable year of Class B Certificateholders, the REMIC Class C Certificateholders, the Class R-LT Certificateholder and the Class R-UT Certificateholder. The Trust shall be a calendar year Fund intends to allocate all excess inclusion income to the Upper-Tier REMIC, and specifically to the Class R-UT Certificateholder. At all times, the Trustee shall maintain or cause take all actions consistent with this intention. In addition, with respect to the maintenance Lower-Tier REMIC, the Trustee shall account for distributions made from the Lower-Tier REMIC as made on the first day of each calendar month. Further, the Trustee shall account for income of the books of Lower-Tier REMIC under the REMIC Trust assets on all-OID method at the accrual Alternate Certificate Rate and shall use the aggregation method of accountingas provided in Treasury Regulation ss. 1.1275-2(c). (b) The Trustee shall prepare and file or cause to be filed with the Internal Revenue Service Federal tax information returns with respect to the REMIC Trust, the Trust Fund, if applicable, and the Certificates containing such information and at the times and in the manner required by the Code or applicable Treasury Regulations all Federal tax or information returns with respect to the Upper-Tier REMIC and the Lower-Tier REMIC and the Certificates, which tax or information returns contain such information as may be required by the Code or applicable Treasury regulationsRegulations. The Class R-LT Certificateholder may, and upon reasonable notice to the Trustee, review such tax or information returns prior to filing with the Internal Revenue Service. The Trustee also shall furnish to each Holder Holders of Certificates at any time during the calendar year for which such returns or reports are made such statements or information at the times and in the manner as the Code or applicable Treasury Regulations may require such holders to be required therebyfurnished, regardless of by whom. In connection with the foregoingFor this purpose, the Trustee shall provide the name and address may, but need not, rely on any proposed regulations of the person who can be contacted to obtain information required to be reported to United States Department of the holders of regular interests in the REMIC Trust (the "REMIC Reporting Agent") as required by IRS Form 8811Treasury. The Trustee shall make indicate the elections election to treat the REMIC Trust Fund (exclusive of the Mortgage 100(SM) Pledge Agreements, the Parent Power(R) Agreements and the Carryover Reserve Fund (including the funds therein)) as a REMIC (which election shall apply to the taxable period ending December 31, 1997 and each calendar year thereafter) two REMICs in such manner as the Code or applicable Treasury regulations may prescribe. The Trustee shall sign all required tax or information returns; provided, however, that the Trustee shall have no obligation to prepare, file or otherwise deal with partnership tax information or returns. In the event that partnership tax information or returns filed pursuant to this Section and any other returns as may be is required by the CodeInternal Revenue Service, the Mortgage Loan Seller will prepare and in doing so shall rely entirely upon, and shall have no liability for information or calculations contained in the Pooled Certificate Distribution Date Statementsfile all necessary returns. The Trustee initial Class R-LT Certificateholder is hereby designated as the initial "Tax Matters Persontax matters person" (within the meaning of Temp. Treas. Reg. ' 1.860F-4(dss. 1.860F-4T(d)) for the REMIC Trust. Any Holder of a Residual Certificate will by acceptance thereof appoint the Trustee as agent and attorney-in-fact for the purpose of acting as Tax Matters Person for the REMIC Trust during such time as the Trustee does not own any such Residual Certificate). In the event that the Code or applicable Treasury regulations Regulations prohibit the Trustee from signing tax or information returns or other statements, or the Trustee Class R-LT Certificateholder from acting as Tax Matters Person tax matters person (as an agent or otherwise), the Trustee shall take whatever action that in its sole good faith judgment is necessary for the proper filing of such information returns or for the provision of a tax matters person, including designation of the Holder of the Residual Certificate Class R-LT Certificateholder to sign such returns or act as tax matters personreturns. Each Holder of The Class R-LT Certificateholder and the Residual Certificate Class R-UT Certificateholder shall each be bound by this Section. (c) The Trustee shall provide upon request such information as is required in Section 860D(a)(6)(B) 5.15. [End of the Code to the Internal Revenue Service, to any Person purporting to transfer a Residual Certificate to a Person other than a transferee permitted by Section 5.05(b), and to any regulated investment company, real estate investment trust, common trust fund, partnership, trust, estate, organization described in Section 1381 of the Code, or nominee holding an interest in a pass-through entity described in Section 860E(e)(6) of the Code, any record holder of which is not a transferee permitted by Section 5.05(b) (or which is deemed by statute to be an entity with a disqualified member). (d) The Trustee shall prepare and file or cause to be filed any state income tax returns required with respect to the REMIC Trust or the Trust Fund.Article V]

Federal Information Returns and Reports to Certificateholders. (a) For Federal income tax purposes, the taxable year of for the REMIC Trust shall be a calendar year and the Trustee shall maintain or cause the maintenance of the books of each of the REMIC Trust assets on the accrual method of accounting. (b) The Trustee shall prepare and file or cause to be filed with the Internal Revenue Service Federal federal tax information returns with respect to the REMIC TrustREMIC, the Trust FundTrust, if applicable, and the Certificates containing such information and at the times and in the manner as may be required by the Code or applicable Treasury regulations, and shall furnish to each Holder of Certificates at any time during the calendar year for which such returns or reports are made such statements or information at the times and in the manner as may be required thereby. In connection with the foregoing, the Trustee shall provide the name and address of the person who can be contacted to obtain information required to be reported to the holders of regular interests in the of REMIC Trust (the "“REMIC Reporting Agent"”) as required by IRS Form 8811. The Trustee shall make the elections to treat the of REMIC Trust as a REMIC (which election shall apply to the taxable period ending December 31, 1997 2002 and each calendar year thereafter) in such manner as the Code or applicable Treasury regulations may prescribe. The Trustee shall sign all tax information returns filed pursuant to this Section and any other returns as may be required by the Code, and in doing so shall rely entirely upon, and shall have no liability for information or calculations contained in the Pooled Certificate Security Distribution Date Statements. The Trustee Holder of the Class R Certificate is hereby designated as the "“Tax Matters Person" ” (within the meaning of Treas. Reg. ' §1.860F-4(d)) for the REMIC TrustREMIC. The Trustee is hereby designated and appointed as the agent of such Tax Matters Person. Any Holder of a Residual Class R Certificate will by acceptance thereof appoint the Trustee as agent and attorney-in-fact for the purpose of acting as Tax Matters Person for the REMIC Trust during such time as the Trustee does not own any such Residual the Class R Certificate. In the event that the Code or applicable Treasury regulations prohibit the Trustee from signing tax or information returns or other statements, or the Trustee from acting as Tax Matters Person (as an agent or otherwise), the Trustee shall take whatever action that in its sole good faith judgment is necessary for the proper filing of such information returns or for the provision of a tax matters person, including designation of the Holder of the Residual Class R Certificate to sign such returns or act as tax matters person. Each Holder of the Residual Class R Certificate shall be bound by this Section. (c) The Trustee shall provide upon request such information as is required in Section 860D(a)(6)(B) of the Code to the Internal Revenue Service, to any Person purporting to transfer a Residual Class R Certificate to a Person other than a transferee permitted by Section 5.05(b4.05(b), and to any regulated investment company, real estate investment trust, common trust fund, partnership, trust, estate, organization described in Section 1381 of the Code, or nominee holding an interest in a pass-through entity described in Section 860E(e)(6) of the Code, any record holder of which is not a transferee permitted by Section 5.05(b4.05(b) (or which is deemed by statute to be an entity with a disqualified member). (d) The Trustee shall prepare and file or cause to be filed any state New York State income tax returns required with respect to the REMIC Trust or the Trust Fundand upon receipt of the notice and confirmation required by the terms of Section 3.06(g) to prepare and file or cause to be filed any tax returns required by any other states with respect to the REMIC or the Trust.

Federal Information Returns and Reports to Certificateholders. (a) For Federal income tax purposes, the taxable year of the REMIC Trust shall be a calendar year and the Trustee shall maintain or cause the maintenance of the books of the each REMIC Trust assets on the accrual method of accounting. (b) The Trustee shall prepare and file or cause to be filed with the Internal Revenue Service Federal tax information returns or elections required to be made by the Trustee hereunder with respect to the any REMIC Trust, the Trust Fund, if applicable, and the Certificates containing such information and at the times and in the manner as may be required by the Code or applicable Treasury regulations, and shall furnish to each Holder of Certificates at any time during the calendar year for which such returns or reports are made such statements or information at the times and in the manner as may be required thereby. In connection with the foregoing, the Trustee shall provide the name and address of the person who can be contacted to obtain information required to be reported to the holders of regular interests in the REMIC Trust (the "REMIC Reporting Agent") as required by IRS Form 8811. The Trustee shall make the elections to treat the REMIC Trust Fund as a REMIC (which election shall apply to the taxable period ending December 31, 1997 1999 and each calendar year thereafter) in such manner as the Code or applicable Treasury regulations may prescribe. The Trustee shall sign all tax information returns filed pursuant to this Section and any other returns as may be required by the Code, and in doing so shall rely entirely upon, and shall have no liability for information provided by, or calculations contained in provided by, the Pooled Certificate Distribution Date StatementsSeller or the Servicer. The Trustee Holder of the Residual Certificate is hereby designated as the "Tax Matters Person" (within the meaning of Treas. Reg. ' 1.860F-4(d▇▇.▇▇.. 1. 860F-4(d)) for the REMIC TrustREMIC. The Trustee is hereby designated and appointed as the agent of each such Tax Matters Person. Any Holder of a Residual Certificate will by acceptance thereof appoint the Trustee as agent and attorney-in-fact for the purpose of acting as Tax Matters Person for the REMIC Trust during such time as the Trustee does not own any such Residual Certificate. In the event that the Code or applicable Treasury regulations prohibit the Trustee from signing tax or information returns or other statements, or the Trustee from acting as Tax Matters Person (as an agent or otherwise), the Trustee shall take whatever action that in its sole good faith judgment is necessary for the proper filing of such information returns or for the provision of a tax matters person, including designation of the Holder of the a Residual Certificate to sign such returns or act as tax matters person. Each Holder of the a Residual Certificate shall be bound by this Section. (c) The Trustee shall provide upon request such information (which shall be provided upon reasonable compensation to the Trustee) as is required in Section 860D(a)(6)(B) of the Code to the Internal Revenue Service, to any Person purporting to transfer a Residual Certificate to a Person other than a transferee permitted by Section 5.05(b), and to any regulated investment company, real estate investment trust, common trust fund, partnership, trust, estate, organization described in Section 1381 of the Code, or nominee holding an interest in a pass-through entity described in Section 860E(e)(6) of the Code, any record holder of which is not a transferee permitted by Section 5.05(b5.02(e) (or which is deemed by statute to be an entity with a disqualified member). (d) The Trustee shall prepare and file or cause to be filed any state income tax returns required under Applicable State Law with respect to the REMIC Trust or the Trust Fund.