Common use of Grantor Trust Reporting Clause in Contracts

Grantor Trust Reporting. (a) The parties intend that the portions of the Trust Fund constituting the Grantor Trust, which consists of (i) the Excess Interest, the Excess Interest Account and proceeds thereof, and (ii) the uncertificated regular interests in the Upper-Tier REMIC represented by any Exchangeable Certificates that have been exchanged and converted for Class EC Certificates, the Class EC Distribution Account and proceeds thereof, shall constitute, and that the affairs of the Trust Fund (exclusive of the Lower-Tier REMIC and the Upper-Tier REMIC) shall be conducted so as to qualify such portion as, a “grantor trust” under subpart E, part I of subchapter J of the Code, and the provisions hereof shall be interpreted consistently with this intention. In furtherance of such intention, neither the Trustee nor the Certificate Administrator shall have the power to vary the investment of the Class EC and Class NR Certificateholders in the Grantor Trust so as to improve their rate of return. The Certificate Administrator shall prepare or cause to be prepared, submit to the Trustee for execution (and the Trustee shall timely execute and timely return to the Certificate Administrator) and timely file all Tax Returns in respect of the Grantor Trust. In addition, the Certificate Administrator shall (A) file, or cause to be filed, Internal Revenue Service Form 1041 (or, in the event the Grantor Trust is a WHFIT, information will be provided on Form 1099) or such other form as may be applicable with the Internal Revenue Service with copies of the statements in the following clause and (B) furnish, or cause to be furnished, to the Class EC and Class NR Certificateholders, their allocable share of income and expense with respect to the Exchangeable Certificates and the Class EC Distribution Account, and the Excess Interest and Excess Interest Distribution Account, respectively, in the time or times and in the manner required by the Code.

Grantor Trust Reporting. (a) The parties intend that the portions portion of the Trust Fund constituting the Grantor Trust, which consists of (i) the Excess Interest, the Excess Interest Account and proceeds thereof, and (ii) the uncertificated regular interests in the Upper-Tier REMIC represented by any Exchangeable Certificates that have been exchanged and converted for Class EC Certificates, the Class EC Distribution Account and proceeds thereof, shall constitute, and that the affairs of the Trust Fund (exclusive of the Lower-Tier REMIC and the Upper-Tier REMIC) shall be conducted so as to qualify such portion as, a “grantor trust” under subpart E, part I of subchapter J of the Code, and the provisions hereof shall be interpreted consistently with this intention. In furtherance of such intention, neither the Trustee nor the Certificate Administrator shall have the power to vary the investment of the Class EC and Class NR Certificateholders in the Grantor Trust so as to improve their rate of return. The Certificate Administrator shall prepare or cause to be prepared, submit to the Trustee for execution (and the Trustee shall timely execute and timely return to the Certificate Administrator) and timely file all Tax Returns in respect of the Grantor Trust. In addition, the Certificate Administrator shall (A) file, or cause to be filed, Internal Revenue Service Form 1041 (or, in the event the Grantor Trust is a WHFIT, information will be provided on Form 1099) or such other form as may be applicable with the Internal Revenue Service with copies of the statements in the following clause and (B) furnish, or cause to be furnished, to the Class EC and Class NR Certificateholders, their allocable share of income and expense with respect to the Exchangeable Certificates and the Class EC Distribution Account, and the Excess Interest and Excess Interest Distribution Account, respectively, in the time or times and in the manner required by the Code.

Grantor Trust Reporting. (a) The parties intend that the portions portion of the Trust Fund constituting the Grantor Trust, which consists of (i) the Excess Interest, the Excess Interest Account and proceeds thereof, and (ii) the uncertificated regular interests in the Upper-Tier REMIC represented by any Exchangeable Certificates that have been exchanged and converted for Class EC Certificates, the Class EC Distribution Account and proceeds thereof, shall constitute, and that the affairs of the Trust Fund (exclusive of the Lower-Tier REMIC and the Upper-Tier REMIC) shall be conducted so as to qualify such portion as, a “grantor trust” under subpart E, part I of subchapter J of the Code, and the provisions hereof shall be interpreted consistently with this intention. In furtherance of such intention, neither the Trustee nor the Certificate Administrator shall have the power to vary the investment of the Class EC and Class NR Certificateholders in the Grantor Trust so as to improve their rate of return. The Certificate Administrator shall prepare or cause to be prepared, submit to the Trustee for execution (and the Trustee shall timely execute and timely return to the Certificate Administrator) and timely file all Tax Returns in respect of the Grantor Trust. In addition, the Certificate Administrator shall (A) file, or cause to be filed, Internal Revenue Service Form 1041 (or, in the event the Grantor Trust is a WHFIT, information will be provided on Form 1099) or such other form as may be applicable with the Internal Revenue Service with copies of the statements in the following clause and (B) furnish, or cause to be furnished, to the Class EC and Class NR Certificateholders, their allocable share of income and expense with respect to the Exchangeable Certificates and the Class EC Distribution Account, and the Excess Interest and Excess Interest Distribution Account, respectively, in the time or times and in the manner required by the Code.

Grantor Trust Reporting. (a) The parties intend that the portions of the Trust Fund constituting the Grantor Trust, which consists of (i) the Excess Interest, the Excess Interest Account and proceeds thereof, thereof and (ii) the uncertificated regular interests in the Upper-Tier REMIC represented by any Exchangeable Certificates that have been exchanged and converted for Class EC Certificates, the Class EC Distribution Account and proceeds thereof, shall constitute, and that the affairs of the Trust Fund (exclusive of the Lower-Tier REMIC and the Upper-Tier REMIC) shall be conducted so as to qualify such portion as, a “grantor trust” under subpart E, part I of subchapter J of the Code, and the provisions hereof shall be interpreted consistently with this intention. In furtherance of such intention, neither the Trustee nor the Certificate Administrator shall have the power to vary the investment of the Class EC and or Class NR Certificateholders in the Grantor Trust so as to improve their rate of return. The Certificate Administrator shall prepare or cause to be prepared, submit to the Trustee for execution (and the Trustee shall timely execute and timely return to the Certificate Administrator) and timely file all Tax Returns in respect of the Grantor Trust. In addition, the Certificate Administrator shall (A) file, or cause to be filed, Internal Revenue Service Form 1041 (or, in the event the Grantor Trust is a WHFIT, information will be provided on Form 1099) or such other form as may be applicable with the Internal Revenue Service with copies of the statements in the following clause and clause, (B) furnish, or cause to be furnished, to the Class EC and Class NR Certificateholders, their allocable share of income and expense with respect to the Exchangeable Certificates and the Class EC Distribution Account, and the Excess Interest and Excess Interest Distribution Account, respectively, in the time or times and in the manner required by the Code.

Grantor Trust Reporting. (a) The parties intend that the portions of the Trust Fund constituting consisting of the Grantor Trust, which consists of (i) right to receive all Excess Interest with respect to the Excess Interest, Mortgage Loans and related amounts held from time to time in the Excess Interest Account and proceeds thereofDistribution Account, and (ii) which will be beneficially owned by the uncertificated regular interests in Holders of the Upper-Tier REMIC represented by any Exchangeable Certificates that have been exchanged and converted for Class EC V Certificates, the Class EC Distribution Account and proceeds thereof, shall constitute, and that the affairs of the Trust Fund (exclusive of the Lower-Tier REMIC and the Upper-Tier REMIC) shall be conducted so treated as to qualify such portion as, a “grantor trust” trust under subpart E, part I of subchapter J of the Code, and the provisions hereof shall be interpreted consistently with this intention. In furtherance of such intention, neither the Trustee nor the Certificate Administrator shall furnish or cause to be furnished annually, and shall file or cause to be filed with the IRS together with Form 1041 or Form 1099 or such other Tax Return or form as may be applicable, to the Holders of [the Class [EC] Certificates and] the Class V Certificates, the amount of any Excess Interest received with respect to the Mortgage Loans. Under no circumstances shall the Certificate Administrator, the Trustee, the Master Servicer or the Special Servicer have the power to vary the investment of the [the Class EC and [EC] Certificates and] Class NR Certificateholders V Certificates in the Grantor Trust so as to take advantage of variations in the market rate of interest to improve their rate of return. The Grantor Trust is a WHFIT that is a WHMT. The Certificate Administrator shall prepare report as required under the WHFIT Regulations, provided that the Certificate Administrator receives on a timely basis any and all information not already in its possession reasonably necessary for it to do so. The Certificate Administrator is hereby directed to assume that the Class V Certificates are not held by a “middleman” (as such term is defined in the WHFIT Regulations) unless the Holder thereof or cause the Depositor provides the Certificate Administrator with the identity of any “middleman” that is the Holder of a Class V Certificate. The Certificate Administrator shall be entitled to rely on the first sentence of this paragraph and shall be preparedentitled to indemnification in accordance with the terms of this Agreement in the event that the IRS makes a determination that the first sentence of this paragraph is incorrect. The Certificate Administrator shall report required WHFIT information using the accrual method, submit except to the Trustee for execution (and extent the Trustee shall timely execute and timely return WHFIT Regulations specifically require a different method. The Certificate Administrator is under no obligation to determine whether the Holder of any Class V Certificate or other beneficial owner of a Class V Certificate, to the extent the Certificate Administrator) and timely file all Tax Returns in respect Administrator knows of any other beneficial owner of a Class V Certificate, uses the Grantor Trustcash or accrual method. The Certificate Administrator shall make available information as required by the WHFIT Regulations to such Holders of Class V Certificates annually. In addition, the Certificate Administrator is not responsible or liable for providing subsequently amended, revised or updated information to any Holder of any Class V Certificate unless requested by such Holder. The Certificate Administrator shall not be liable for failure to meet the reporting requirements of the WHFIT Regulations nor for any penalties thereunder (Awhich shall solely be the responsibility of the related Holders of Class V Certificates) fileif such failure is due to: (i) the lack of reasonably necessary information that is not in its possession being provided to the Certificate Administrator, or cause to be filed(ii) incomplete, Internal Revenue Service Form 1041 (or, in the event the Grantor Trust is a WHFIT, inaccurate or untimely information will be being provided on Form 1099) or such other form as may be applicable with the Internal Revenue Service with copies of the statements in the following clause and (B) furnish, or cause to be furnished, to the Class EC Certificate Administrator. Absent receipt of information regarding any sale of securities, including the price, amount of proceeds and Class NR Certificateholdersdate of sale from the beneficial owner thereof or the Depositor, their allocable share the Certificate Administrator shall assume there is no secondary market trading of income and expense with respect to WHFIT interests. To the Exchangeable Certificates and the Class EC Distribution Account, and the Excess Interest and Excess Interest Distribution Account, respectively, in the time or times and in the manner extent required by the CodeWHFIT Regulations, the Certificate Administrator shall use reasonable efforts to publish on an appropriate website the CUSIP Numbers for the Class V Certificates that represent ownership of a WHFIT. The Certificate Administrator shall make reasonable good faith efforts to keep the website accurate and updated to the extent CUSIP Numbers have been received. The Certificate Administrator is not liable for investor reporting delays that result from the receipt of inaccurate or untimely CUSIP Number information.]

Grantor Trust Reporting. (a) The parties intend that the portions of the Trust Fund constituting the Grantor Trust, which consists of (i) the Excess Interest, the Excess Interest Account and proceeds thereof, and (ii) the uncertificated regular interests in the Upper-Tier REMIC represented by any Exchangeable Certificates that have been exchanged and converted for Class EC Certificates, the Class EC Distribution Account and proceeds thereof, shall constitute, and that the affairs of the Trust Fund (exclusive of the Lower-Tier REMIC and REMIC, the Upper-Tier REMIC and U-Haul Self Storage Pool 5 Trust Pari Passu Companion Loan REMIC) shall be conducted so as to qualify such portion as, a “grantor trust” under subpart E, part I of subchapter J of the Code, and the provisions hereof shall be interpreted consistently with this intention. In furtherance of such intention, neither the Trustee nor the Certificate Administrator shall have the power to vary the investment of the Class EC and Class NR Z Certificateholders in the Grantor Trust so as to improve their rate of return. The Certificate Administrator shall prepare or cause to be prepared, submit to the Trustee for execution (and the Trustee shall timely execute and timely return to the Certificate Administrator) and timely file all Tax Returns in respect of the Grantor Trust. In addition, the Certificate Administrator shall (A) file, or cause to be filed, Internal Revenue Service Form 1041 (or, in the event the Grantor Trust is a WHFIT, information will be provided on Form 1099) or such other form as may be applicable with the Internal Revenue Service with copies of the statements in the following clause and (B) furnish, or cause to be furnished, to the Class EC and Class NR Z Certificateholders, their allocable share of income and expense with respect to the Exchangeable Certificates and the Class EC Distribution Account, and the Excess Interest and Excess Interest Distribution Account, respectively, in the time or times and in the manner required by the Code.

Grantor Trust Reporting. (a) The parties intend that the portions of the Trust Fund constituting the Grantor Trust, which consists consisting of (i) the Default Interest, proceeds therefrom, the AIMCO Multifamily Pool Conditional Debt, proceeds therefrom, and the Class Q Distribution Account, (ii) Excess Interest, proceeds therefrom and the Excess Interest Account and proceeds thereofDistribution Account, and (iiiii) the uncertificated regular interests in the Upper-Tier REMIC represented by any Exchangeable Certificates that have been exchanged Reinvestment Enhancement Instrument and converted for Class EC Certificates, the Class EC Distribution Reinvestment Reserve Account and proceeds thereof, shall constitute, and that the affairs of the Trust Fund (exclusive of the Lower-Tier REMIC and the Upper-Tier REMICTrust REMICs) shall be conducted so as to qualify such portion as, a “"grantor trust” " under subpart E, part I of subchapter J of the Code, and the provisions hereof shall be interpreted consistently with this intention. In furtherance of such intention, neither the Trustee nor the Certificate Administrator shall have the power to vary the investment of the Class EC and Class NR Certificateholders in the Grantor Trust so as to improve their rate of return. The Certificate Administrator shall prepare furnish or cause to be prepared, submit furnished to the Trustee for execution (Certificateholders and the Trustee shall timely execute and timely return to the Certificate Administrator) and timely file all Tax Returns in respect of the Grantor Trust. In addition, the Certificate Administrator shall (A) file, or cause to be filed, filed with the Internal Revenue Service together with Form 1041 (or, in the event the Grantor Trust is a WHFIT, information will be provided on Form 1099) or such other form as may be applicable with applicable, (i) to the Internal Revenue Service with copies Holders of the statements in the following clause and (B) furnishClass Q Certificates, or cause income with respect to be furnished, to the Class EC and Class NR Certificateholders, their allocable share of income Default Interest and expense with respect the amount of any interest paid on unreimbursed Advances to the Exchangeable Certificates Master Servicer, the Trustee and the Class EC Distribution AccountFiscal Agent, and as applicable, therefrom pursuant to Section 3.06(iii) the Excess Interest and Excess Interest Distribution Accountamount of all collections on the AIMCO Multifamily Pool Conditional Debt, respectively, in at the time or times and in the manner required by the Code, (ii) to the Holders of the Classes of Regular Certificates entitled thereto as set forth in Section 2.06(b), income with respect to their allocable share of Excess Interest at the time or times and in the manner required by the Code and (iii) Xxxxxxx Group or its designee, income or expense with respect to the Reinvestment Enhancement Instrument and the Reinvestment Reserve Account.

Grantor Trust Reporting. (a) The parties intend that the portions of the Trust Fund constituting the Grantor Trust, which consists of (i) the Excess Interest, the Excess Interest Account and proceeds thereof, and (ii) the uncertificated regular interests in the Upper-Tier REMIC represented by any Exchangeable Certificates that have been exchanged and converted for Class EC Certificates, the Class EC Distribution Account and proceeds thereof, shall constitute, and that the affairs of the Trust Fund (exclusive of the Lower-Tier REMIC and the Upper-Tier REMIC) shall be conducted so as to qualify such portion as, a “grantor trust” under subpart E, part I of subchapter J of the Code, and the provisions hereof shall be interpreted consistently with this intention. In furtherance of such intention, neither the Trustee nor the Certificate Administrator shall have the power to vary the investment of the Class EC and Class NR Z Certificateholders in the Grantor Trust so as to improve their rate of return. The Certificate Administrator shall prepare or cause to be prepared, submit to the Trustee for execution (and the Trustee shall timely execute and timely return to the Certificate Administrator) and timely file all Tax Returns in respect of the Grantor Trust. In addition, the Certificate Administrator shall (A) file, or cause to be filed, Internal Revenue Service Form 1041 (or, in the event the Grantor Trust is a WHFIT, information will be provided on Form 1099) or such other form as may be applicable with the Internal Revenue Service with copies of the statements in the following clause and (B) furnish, or cause to be furnished, to the Class EC and Class NR Z Certificateholders, their allocable share of income and expense with respect to the Exchangeable Certificates and the Class EC Distribution Account, and the Excess Interest and Excess Interest Distribution Account, respectively, in the time or times and in the manner required by the Code.

Grantor Trust Reporting. (a) The parties intend that the portions of the Trust Fund constituting the Grantor Trust, which consists consisting of (i) the Default Interest, proceeds therefrom and the Class Q Distribution Account, (ii) Excess Interest, proceeds therefrom and the Excess Interest Distribution Account and proceeds thereof, and (iiiii) the uncertificated regular interests in the Upper-Tier REMIC represented by any Exchangeable Certificates that have been exchanged and converted for Class EC CertificatesMarriott Desert Springs Parent Loan, proceeds therefrom, the Class EC M Collection Account and the Class M Distribution Account and proceeds thereof, shall constitute, and that the affairs of the Trust Fund (exclusive of the Lower-Tier REMIC and the Upper-Tier REMICTrust REMICs) shall be conducted so as to qualify such portion as, a “"grantor trust” " under subpart E, part I of subchapter J of the Code, and the provisions hereof shall be interpreted consistently with this intention. In furtherance of such intention, neither the Trustee nor the Certificate Administrator shall have the power to vary the investment of the Class EC and Class NR Certificateholders in the Grantor Trust so as to improve their rate of return. The Certificate Administrator shall prepare furnish or cause to be prepared, submit furnished to the Trustee for execution (Certificateholders and the Trustee shall timely execute and timely return to the Certificate Administrator) and timely file all Tax Returns in respect of the Grantor Trust. In addition, the Certificate Administrator shall (A) file, or cause to be filed, filed with the Internal Revenue Service together with Form 1041 (or, in the event the Grantor Trust is a WHFIT, information will be provided on Form 1099) or such other form as may be applicable with applicable, (i) to the Internal Revenue Service with copies Holders of the statements in the following clause and (B) furnishClass Q Certificates, or cause income with respect to be furnished, to the Class EC and Class NR Certificateholders, their allocable share of Default Interest and the amount of any interest paid on unreimbursed Advances to the Master Servicer, the Trustee and the Fiscal Agent, as applicable, therefrom pursuant to Section 3.06(iii) at the time or times and in the manner required by the Code, (ii) to the Holders of the Classes of Regular Certificates entitled thereto as set forth in Section 2.06(b), income with respect to their allocable share of Excess Interest at the time or times and expense in the manner required by the Code, and (iii) to the Holders of the Class M and Class MX Certificates, income with respect to their allocable shares of the interest portion of any payments received on or with respect to the Exchangeable Certificates Marriott Desert Springs Parent Loan and their allocable shares of any other income with respect to the Class EC Distribution AccountMarriott Desert Springs Parent Loan, and their allocable shares of the Excess Servicing Fee, the Trustee Fee or other expenses incurred by the Trust Fund with respect to the Marriott Desert Springs Parent Loan, such allocable shares to be based on the ratio of their respective Pass-Through Rates to the MDSPL Interest and Excess Interest Distribution AccountRate, respectively, in at the time or times and in the manner required by the Code.

Grantor Trust Reporting. (a) The parties intend that the portions of the Trust Fund constituting consisting of the Grantor Trust, which consists of (i) right to receive all Excess Interest with respect to the Excess Interest, Mortgage Loans and related amounts held from time to time in the Excess Interest Account and proceeds thereofDistribution Account, and (ii) which will be beneficially owned by the uncertificated regular interests in Holders of the Upper-Tier REMIC represented by any Exchangeable Certificates that have been exchanged and converted for Class EC S Certificates, the Class EC Distribution Account and proceeds thereof, shall constitute, and that the affairs of the Trust Fund (exclusive of the Lower-Tier REMIC and the Upper-Tier REMIC) shall be conducted so treated as to qualify such portion as, a “grantor trust” trust under subpart E, part I of subchapter J of the Code, and the provisions hereof shall be interpreted consistently with this intention. In furtherance of such intention, neither the Trustee nor the Certificate Administrator shall furnish or cause to be furnished annually, and shall file or cause to be filed with the IRS together with Form 1041 or Form 1099 or such other Tax Return or form as may be applicable, to the Holders of the Class S Certificates, the amount of any Excess Interest received with respect to the Mortgage Loans. Under no circumstances shall the Certificate Administrator, the Trustee, the Master Servicer or the Special Servicer have the power to vary the investment of the Class EC and Class NR Certificateholders S Certificates in the Grantor Trust so as to take advantage of variations in the market rate of interest to improve their rate of return. If the Certificate Administrator determines that any Class S Certificate is held through a nominee, then the Grantor Trust will be treated as a WHFIT that is a WHMT. In such event, the Certificate Administrator shall report as required under the WHFIT Regulations, provided that the Certificate Administrator receives on a timely basis any and all information not already in its possession reasonably necessary for it to do so. The Certificate Administrator shall prepare or cause be entitled to rely on its determination that a Class S Certificate is held through a middleman and shall be preparedentitled to indemnification in accordance with the terms of this Agreement in the event that the IRS makes a determination that such determination is incorrect. As of the Closing Date, submit the Class S Certificate is not held through a nominee. The Certificate Administrator shall report required WHFIT information using the accrual method, except to the Trustee for execution (and extent the Trustee shall timely execute and timely return WHFIT Regulations specifically require a different method. The Certificate Administrator is under no obligation to determine whether the Holder of any Class S Certificate or other beneficial owner of a Class S Certificate, to the extent the Certificate Administrator) and timely file all Tax Returns in respect Administrator knows of any other beneficial owner of a Class S Certificate, uses the Grantor Trustcash or accrual method. The Certificate Administrator shall make available information as required by the WHFIT Regulations to such Holders of Class S Certificates annually. In addition, the Certificate Administrator is not responsible or liable for providing subsequently amended, revised or updated information to any Holder of any Class S Certificate unless requested by such Holder. The Certificate Administrator shall not be liable for failure to meet the reporting requirements of the WHFIT Regulations nor for any penalties thereunder (Awhich shall solely be the responsibility of the related Holders of Class S Certificates) fileif such failure is due to: (i) the lack of reasonably necessary information that is not in its possession being provided to the Certificate Administrator, or cause to be filed(ii) incomplete, Internal Revenue Service Form 1041 (or, in the event the Grantor Trust is a WHFIT, inaccurate or untimely information will be being provided on Form 1099) or such other form as may be applicable with the Internal Revenue Service with copies of the statements in the following clause and (B) furnish, or cause to be furnished, to the Class EC Certificate Administrator. Absent receipt of information regarding any sale of securities, including the price, amount of proceeds and Class NR Certificateholdersdate of sale from the beneficial owner thereof or the Depositor, their allocable share the Certificate Administrator shall assume there is no secondary market trading of income and expense with respect to WHFIT interests. To the Exchangeable Certificates and the Class EC Distribution Account, and the Excess Interest and Excess Interest Distribution Account, respectively, in the time or times and in the manner extent required by the CodeWHFIT Regulations, the Certificate Administrator shall use reasonable efforts to publish on an appropriate website the CUSIP Numbers for the Class S Certificates that represent ownership of a WHFIT. The Certificate Administrator shall make reasonable good faith efforts to keep the website accurate and updated to the extent CUSIP Numbers have been received. The Certificate Administrator is not liable for investor reporting delays that result from the receipt of inaccurate or untimely CUSIP Number information.

Grantor Trust Reporting. (a) The parties intend that the portions portion of the Trust Fund constituting the Grantor Trust, which consists of (i) the Excess InterestInterest allocable to the Mortgage Loans, proceeds thereof held in the Certificate Account pertaining to the Excess Interest allocable to the Mortgage Loans and the Excess Interest Distribution Account and proceeds thereof, and (ii) the uncertificated regular interests in the Upper-Tier REMIC represented by any Exchangeable Certificates that have been exchanged and converted for Class EC CertificatesA-2SFL Regular Interest, the Class EC Distribution Account A-JFL Regular Interest, the Swap Contracts, the Floating Rate Accounts and proceeds thereof, shall constitute, and that the affairs of the Trust Fund (exclusive of the Lower-Tier REMIC, the Middle-Tier REMIC and the Upper-Tier REMIC) shall be conducted so as to qualify such portion as, a “"grantor trust” " under subpart E, part Part I of subchapter J of the Code, and the provisions hereof shall be interpreted consistently with this intention. In furtherance of such intention, neither the Trustee nor the Certificate Administrator shall have the no power to vary the investment of the Class EC A-2SFL and Class NR A-JFL Certificateholders in the Grantor Trust their related assets so as to improve their rate of return. The Certificate Administrator In addition, the Trustee shall prepare (A) as soon as possible after the Swap Contracts are entered into (but no later than the first payment date under the Swap Contracts), obtain a taxpayer identification number for the Grantor Trust and deliver or cause to be prepared, submit to delivered the Trustee for execution (and the Trustee shall timely execute and timely return to the Certificate Administrator) and timely file all Tax Returns in respect federal taxpayer identification number of the Grantor Trust. In additionTrust on an IRS Form W-9 to each Swap Counterparty and, if requested by the Certificate Administrator shall Swap Counterparty (Aunless not permitted under federal income tax law), an applicable IRS Form W-8IMY, (B) file, or cause to be filed, Internal Revenue Service Form 1041 (or, in the event the Grantor Trust is a WHFIT, information will be provided on Form 1099) or such other form as may be applicable with the Internal Revenue Service with copies of the statements in the following clause and clause, (BC) furnish, or cause to be furnished, to the Class EC A-2SFL Certificateholders and the Class NR A-JFL Certificateholders, their allocable share of income and expense with respect to the Exchangeable Certificates Class A-2SFL Regular Interest and the Class EC Distribution Account, A-JFL Regular Interest and the Excess Interest and Excess Interest Distribution AccountSwap Contracts, respectively, each in the time or times and in the manner required by the Code.Code and (D) furnish, or cause to be furnished, to the Class S Certificateholders, their allocable share of income with respect to Excess Interest accrued or received, as applicable. [End of Article IV]

Grantor Trust Reporting. (a) The parties intend that the portions portion of the Trust Fund constituting the Grantor Trust, which consists of (i) the Excess InterestInterest allocable to the Mortgage Loans, proceeds thereof held in the Certificate Account pertaining to the Excess Interest allocable to the Mortgage Loans and the Excess Interest Distribution Account and proceeds thereof, and (ii) the uncertificated regular interests in the Upper-Tier REMIC represented by any Exchangeable Certificates that have been exchanged and converted for Class EC CertificatesA-2FL Regular Interest, the Class EC Distribution Swap Contract, the Floating Rate Account and proceeds thereof, shall constitute, and that the affairs of the Trust Fund (exclusive of the Lower-Tier REMIC and the Upper-Tier REMIC) shall be conducted so as to qualify such portion as, a “"grantor trust” " under subpart E, part Part I of subchapter J of the Code, and the provisions hereof shall be interpreted consistently with this intention. In furtherance of such intention, neither the Trustee nor the Certificate Administrator shall have the no power to vary the investment of the Class EC and Class NR A-2FL Certificateholders in the Grantor Trust their related assets so as to improve their rate of return. The Certificate Administrator In addition, the Trustee shall prepare (A) as soon as possible after the Swap Contract is entered into (but no later than the first payment date under the Swap Contract), obtain a taxpayer identification number of the Grantor Trust and deliver or cause to be prepared, submit to delivered the Trustee for execution (and the Trustee shall timely execute and timely return to the Certificate Administrator) and timely file all Tax Returns in respect federal taxpayer identification number of the Grantor Trust. In additionTrust on an IRS Form W-9 to the Swap Counterparty and, if requested by the Certificate Administrator Swap Counterparty (unless not permitted under federal income tax law), an applicable IRS Form W-8IMY; provided that Trustee shall not be responsible for failure to obtain a taxpayer identification number for the Grantor Trust if the Trustee timely takes all requisite action and such failure relates solely to a delay by the IRS in issuing such taxpayer identification number, (AB) file, or cause to be filed, Internal Revenue Service Form 1041 (or, in the event the Grantor Trust is a WHFIT, information will be provided on Form 1099) or such other form as may be applicable with the Internal Revenue Service with copies of the statements in the following clause and clause, (BC) furnish, or cause to be furnished, to the Class EC and Class NR A-2FL Certificateholders, their allocable share of income and expense with respect to the Exchangeable Certificates Class A-2FL Regular Interest and the Class EC Distribution AccountSwap Contract, and the Excess Interest and Excess Interest Distribution Account, respectively, each in the time or times and in the manner required by the Code.Code and (D) furnish, or cause to be furnished, to the Class S Certificateholders, their allocable share of income with respect to Excess Interest accrued or received, as applicable. The Grantor Trust is a WHFIT that is a WHMT. The Trustee will report as required under the WHFIT Regulations to the extent such information as is reasonably necessary to enable the Trustee to do so is provided to the Trustee on a timely basis. The Trustee is hereby directed to assume that DTC is the only "middleman" as defined by the WHFIT Regulations unless the Depositor provides the Trustee with the identities of other "middlemen" that are Certificateholders. The Trustee shall be entitled to rely on the first sentence of this paragraph and shall be entitled to indemnification in accordance with the terms of this Agreement in the event that the Internal Revenue Service makes a determination that the first sentence of this paragraph is incorrect. The Trustee, in its discretion, shall report required WHFIT information using either the cash or accrual method, except to the extent the WHFIT Regulations specifically require a different method. The Trustee shall be under no obligation to determine whether any Certificateholder uses the cash or accrual method. The Trustee shall make available (via its website) WHFIT information to Certificateholders annually. In addition, the Trustee shall not be responsible or liable for providing subsequently amended, revised or updated information to any Certificateholder, unless requested by the Certificateholder. The Trustee shall not be liable for failure to meet the reporting requirements of the WHFIT Regulations nor for any penalties thereunder if such failure is due to: (i) the lack of reasonably necessary information being provided to the Trustee, (ii) incomplete, inaccurate or untimely information being provided to the Trustee or (iii) the inability of the Trustee, after good faith efforts, to alter its existing information reporting systems to capture information necessary to fully comply with the WHFIT Regulations for the 2007 calendar year. Each owner of a class of securities representing, in whole or in part, beneficial ownership of an interest in a WHFIT, by acceptance of its interest in such class of securities, will be deemed to have agreed to provide the Trustee with information regarding any sale of such securities, including the price, amount of proceeds and date of sale. Absent receipt of information regarding any sale of Certificates, including the price, amount of proceeds and date of sale from the beneficial owner thereof or the Depositor, the Trustee shall assume there is no secondary market trading of WHFIT interests. To the extent required by the WHFIT Regulations, the Trustee shall use reasonable efforts to publish on an appropriate website the CUSIPs for the Certificates that represent ownership of a WHFIT. The CUSIPs so published will represent the Rule 144A CUSIPs. The Trustee shall make reasonable good faith efforts to keep the website accurate and updated to the extent CUSIPs have been received. Absent the receipt of a CUSIP, the Trustee will use a reasonable identifier number in lieu of a CUSIP. The Trustee shall not be liable for investor reporting delays that result from the receipt of inaccurate or untimely CUSIP information. The Trustee shall be entitled to additional reasonable compensation for changes in reporting required in respect of the WHFIT Regulations that arise as a result of a change in the WHFIT Regulations or a change in interpretation of the WHFIT Regulations by the IRS or the Depositor or its counsel, if such change requires, in the Trustee's sole discretion, a material increase in the Trustee's reporting obligations in respect of the related Grantor Trust. [End of Article IV]

Grantor Trust Reporting. (a) The parties intend that the portions of the Trust Fund constituting consisting of the Grantor Trust, which consists of (i) right to receive all Excess Interest with respect to the Excess Interest, Mortgage Loans and related amounts held from time to time in the Excess Interest Account and proceeds thereofDistribution Account, and (ii) which will be beneficially owned by the uncertificated regular interests in Holders of the Upper-Tier REMIC represented by any Exchangeable Certificates that have been exchanged and converted for Class EC S Certificates, the Class EC Distribution Account and proceeds thereof, shall constitute, and that the affairs of the Trust Fund (exclusive of the Lower-Tier REMIC and the Upper-Tier REMIC) shall be conducted so treated as to qualify such portion as, a “grantor trust” trust under subpart E, part I of subchapter J of the Code, and the provisions hereof shall be interpreted consistently with this intention. In furtherance of such intention, neither the Trustee nor the Certificate Administrator shall furnish or cause to be furnished annually, and shall file or cause to be filed with the IRS together with Form 1041 or Form 1099 or such other Tax Return or form as may be applicable, to the Holders of the Class S Certificates, the amount of any Excess Interest received with respect to the Mortgage Loans. Under no circumstances shall the Certificate Administrator, the Trustee, the Master Servicer or the Special Servicer have the power to vary the investment of the Class EC and Class NR Certificateholders S Certificates in the Grantor Trust so as to take advantage of variations in the market rate of interest to improve their rate of return. The Grantor Trust is a WHFIT that is a WHMT. The Certificate Administrator shall prepare report as required under the WHFIT Regulations, provided that the Certificate Administrator receives on a timely basis any and all information not already in its possession reasonably necessary for it to do so. The Certificate Administrator is hereby directed to assume that the Class S Certificates are not held by a “middleman” (as such term is defined in the WHFIT Regulations) unless the Holder thereof or cause the Depositor provides the Certificate Administrator with the identity of any “middleman” that is the Holder of a Class S Certificate. The Certificate Administrator shall be entitled to rely on the first sentence of this paragraph and shall be preparedentitled to indemnification in accordance with the terms of this Agreement in the event that the IRS makes a determination that the first sentence of this paragraph is incorrect. The Certificate Administrator shall report required WHFIT information using the accrual method, submit except to the Trustee for execution (and extent the Trustee shall timely execute and timely return WHFIT Regulations specifically require a different method. The Certificate Administrator is under no obligation to determine whether the Holder of any Class S Certificate or other beneficial owner of a Class S Certificate, to the extent the Certificate Administrator) and timely file all Tax Returns in respect Administrator knows of any other beneficial owner of a Class S Certificate, uses the Grantor Trustcash or accrual method. The Certificate Administrator shall make available information as required by the WHFIT Regulations to such Holders of Class S Certificates annually. In addition, the Certificate Administrator is not responsible or liable for providing subsequently amended, revised or updated information to any Holder of any Class S Certificate unless requested by such Holder. The Certificate Administrator shall not be liable for failure to meet the reporting requirements of the WHFIT Regulations nor for any penalties thereunder (Awhich shall solely be the responsibility of the related Holders of Class S Certificates) fileif such failure is due to: (i) the lack of reasonably necessary information that is not in its possession being provided to the Certificate Administrator, or cause to be filed(ii) incomplete, Internal Revenue Service Form 1041 (or, in the event the Grantor Trust is a WHFIT, inaccurate or untimely information will be being provided on Form 1099) or such other form as may be applicable with the Internal Revenue Service with copies of the statements in the following clause and (B) furnish, or cause to be furnished, to the Class EC Certificate Administrator. Absent receipt of information regarding any sale of securities, including the price, amount of proceeds and Class NR Certificateholdersdate of sale from the beneficial owner thereof or the Depositor, their allocable share the Certificate Administrator shall assume there is no secondary market trading of income and expense with respect to WHFIT interests. To the Exchangeable Certificates and the Class EC Distribution Account, and the Excess Interest and Excess Interest Distribution Account, respectively, in the time or times and in the manner extent required by the CodeWHFIT Regulations, the Certificate Administrator shall use reasonable efforts to publish on an appropriate website the CUSIP Numbers for the Class S Certificates that represent ownership of a WHFIT. The Certificate Administrator shall make reasonable good faith efforts to keep the website accurate and updated to the extent CUSIP Numbers have been received. The Certificate Administrator is not liable for investor reporting delays that result from the receipt of inaccurate or untimely CUSIP Number information.]

Grantor Trust Reporting. (a) The parties intend that the portions portion of the Trust Fund constituting the Grantor Trust, which consists of (i) the Excess Interest, the Excess Interest Account and proceeds thereof, thereof and (ii) the uncertificated regular interests in Class A-4FL/4FX Regular Interest, the Upper-Tier REMIC represented by any Exchangeable Certificates that have been exchanged and converted for Class EC CertificatesSwap Contract, the Class EC A-4FL/4FX Distribution Account (and the related sub-accounts, if any) and proceeds thereof, shall constitute, and that the affairs of the Trust Fund (exclusive of the Lower-Tier REMIC and the Upper-Tier REMIC) shall be conducted so as to qualify such portion as, a “grantor trust” under subpart E, part I of subchapter J of the Code, and the provisions hereof shall be interpreted consistently with this intention. In furtherance of such intention, neither the Trustee nor the Certificate Administrator shall have the power to vary the investment of the Class EC NR or the Class A-4FX and Class NR A-4FL Certificateholders in the Grantor Trust so as to improve their rate of return. The Certificate Administrator shall prepare or cause to be prepared, submit to the Trustee for execution (and the Trustee shall timely execute and timely return to the Certificate Administrator) and timely file all Tax Returns in respect of the Grantor Trust. In addition, the Certificate Administrator shall (A) as soon as possible after the Swap Contract is entered into (but no later than the first payment date under the Swap Contract), obtain a taxpayer identification number of the Grantor Trust and deliver or cause to be delivered the federal taxpayer identification number of the Grantor Trust on an Internal Revenue Service Form W-9 to the Swap Counterparty and, if requested by the Swap Counterparty (unless not permitted under federal income tax law), an applicable Internal Revenue Service Form W-8IMY; provided that Certificate Administrator shall not be responsible for failure to obtain a taxpayer identification number for the Grantor Trust if the Certificate Administrator timely takes all requisite action and such failure relates solely to a delay by the Internal Revenue Service in issuing such taxpayer identification number, (B) file, or cause to be filed, Internal Revenue Service Form 1041 (or, in the event the Grantor Trust is a WHFIT, information will be provided on Form 1099) or such other form as may be applicable with the Internal Revenue Service with copies of the statements in the following clause and (BC) furnish, or cause to be furnished, to the Class EC and Class NR Certificateholders, their allocable share of income and expense with respect to the Exchangeable Certificates and the Class EC Distribution Account, and the Excess Interest and Excess Interest Distribution Account, respectively, in the time or times and in the manner required by the Code, and (D) furnish, or cause to be furnished, to the Class A-4FX and Class A-4FL Certificateholders, their allocable share of income and expense with respect to the Class A-4FX Specific Grantor Trust Assets and the Class A-4FL Specific Grantor Trust Assets, respectively, each in the time or times and in the manner required by the Code.

Grantor Trust Reporting. (a) The parties intend that the portions of the Trust Fund constituting the Grantor Trust, which consists consisting of (i) the right to receive all Excess Interest, Interest with respect to the Mortgage Loans and related amounts held from time to time in the Excess Interest Account and proceeds thereofDistribution Account, which will be beneficially owned by the Holders of the Class S Certificates and (ii) the uncertificated regular interests Loan REMIC Residual Interests and related amounts held from time to time in the Upper-Tier Loan REMIC represented Residual Distribution Account, which will be beneficially owned by any Exchangeable Certificates that have been exchanged and converted for the Holders of the Class EC R Certificates, the Class EC Distribution Account and proceeds thereof, shall constitute, and that the affairs of the Trust Fund (exclusive of the Lower-Tier REMIC and the Upper-Tier REMIC) shall be conducted so treated as to qualify such portion as, a “grantor trust” trust under subpart E, part I of subchapter J of the Code, and the provisions hereof shall be interpreted consistently with this intention. In furtherance of such intention, neither the Trustee nor the Certificate Administrator shall obtain a taxpayer identification number for the Grantor Trust on IRS Form SS-4 and shall furnish or cause to be furnished annually, and shall file or cause to be filed with the IRS together with Form 1041 or Form 1099 or such other Tax Return or form as may be applicable, to the Holders of the Class S Certificates, the amount of any Excess Interest received with respect to the Mortgage Loans and to the Holders of the Class R Certificates their allocable share of income with respect to the Loan REMIC Residual interests. Under no circumstances shall the Certificate Administrator, the Trustee, the Master Servicer or the Special Servicer have the power to vary the investment of the Class EC and S or the Class NR Certificateholders R Certificates in the Grantor Trust so as to take advantage of variations in the market rate of interest to improve their rate of return. If the Certificate Administrator determines that any Class S or Class R Certificate is held through a nominee, then the Grantor Trust will be treated as a WHFIT that is a WHMT. In such event, the Certificate Administrator shall report as required under the WHFIT Regulations, provided that the Certificate Administrator receives on a timely basis any and all information not already in its possession reasonably necessary for it to do so. The Certificate Administrator shall prepare be entitled to rely on its determination that a Class S or cause Class R Certificate is held through a middleman and shall be entitled to be preparedindemnification in accordance with the terms of this Agreement in the event that the IRS makes a determination that such determination is incorrect. As of the Closing Date, submit the Class S and Class R Certificates are not held through a nominee. The Certificate Administrator shall report required WHFIT information using the accrual method, except to the Trustee for execution (and extent the Trustee shall timely execute and timely return WHFIT Regulations specifically require a different method. The Certificate Administrator is under no obligation to determine whether the Holder of any Class S or Class R Certificate or other beneficial owner of a Class S or Class R Certificate, to the extent the Certificate Administrator) and timely file all Tax Returns in respect Administrator knows of any other beneficial owner of a Class S or Class R Certificate, uses the Grantor Trustcash or accrual method. The Certificate Administrator shall make available information as required by the WHFIT Regulations to such Holders of Class S or Class R Certificates annually. In addition, the Certificate Administrator is not responsible or liable for providing subsequently amended, revised or updated information to any Holder of any Class S or Class R Certificate unless requested by such Holder. The Certificate Administrator shall not be liable for failure to meet the reporting requirements of the WHFIT Regulations nor for any penalties thereunder (Awhich shall solely be the responsibility of the related Holders of Class S and Class R Certificates) fileif such failure is due to: (i) the lack of reasonably necessary information that is not in its possession being provided to the Certificate Administrator, or cause to be filed(ii) incomplete, Internal Revenue Service Form 1041 (or, in the event the Grantor Trust is a WHFIT, inaccurate or untimely information will be being provided on Form 1099) or such other form as may be applicable with the Internal Revenue Service with copies of the statements in the following clause and (B) furnish, or cause to be furnished, to the Class EC Certificate Administrator. Absent receipt of information regarding any sale of securities, including the price, amount of proceeds and Class NR Certificateholdersdate of sale from the beneficial owner thereof or the Depositor, their allocable share the Certificate Administrator shall assume there is no secondary market trading of income and expense with respect to WHFIT interests. To the Exchangeable Certificates and the Class EC Distribution Account, and the Excess Interest and Excess Interest Distribution Account, respectively, in the time or times and in the manner extent required by the CodeWHFIT Regulations, the Certificate Administrator shall use reasonable efforts to publish on an appropriate website the CUSIP Numbers for the Class S and Class R Certificates that represent ownership of a WHFIT. The Certificate Administrator shall make reasonable good faith efforts to keep the website accurate and updated to the extent CUSIP Numbers have been received. The Certificate Administrator is not liable for investor reporting delays that result from the receipt of inaccurate or untimely CUSIP Number information.

Grantor Trust Reporting. (a) The parties intend that the portions of the Trust Fund constituting the Grantor Trust, which consists of (i) the Excess Interest, the Excess Interest Account and proceeds thereof, and (ii) the uncertificated regular interests in the Upper-Tier REMIC represented by any Exchangeable Certificates that have been exchanged and converted for Class EC Certificates, the Class EC Distribution Account and proceeds thereof, shall constitute, and that the affairs of the Trust Fund (exclusive of the Lower-Tier REMIC and the Upper-Tier REMIC) shall be conducted so as to qualify such portion as, a “grantor trust” under subpart E, part I of subchapter J of the Code, and the provisions hereof shall be interpreted consistently with this intention. In furtherance of such intention, neither the Trustee nor the Certificate Administrator shall have the power to vary the investment of the Class EC and or Class NR Z Certificateholders in the Grantor Trust so as to improve their rate of return. The Certificate Administrator shall prepare or cause to be prepared, submit to the Trustee for execution (and the Trustee shall timely execute and timely return to the Certificate Administrator) and timely file all Tax Returns in respect of the Grantor Trust. In addition, the Certificate Administrator shall (A) file, or cause to be filed, Internal Revenue Service Form 1041 (or, in the event the Grantor Trust is a WHFIT, information will be provided on Form 1099) or such other form as may be applicable with the Internal Revenue Service with copies of the statements in the following clause and (B) furnish, or cause to be furnished, to the Class EC and Class NR Z Certificateholders, their allocable share of income and expense with respect to the Exchangeable Certificates and the Class EC Distribution Account, and the Excess Interest and Excess Interest Distribution Account, respectively, in the time or times and in the manner required by the Code.

Grantor Trust Reporting. (a) The parties intend that the portions of the Trust Fund constituting consisting of the Grantor Trust, which consists of (i) right to receive all Excess Interest with respect to the Excess Interest, Mortgage Loans and related amounts held from time to time in the Excess Interest Account and proceeds thereofDistribution Account, and (ii) which will be beneficially owned by the uncertificated regular interests in Holders of the Upper-Tier REMIC represented by any Exchangeable Certificates that have been exchanged and converted for Class EC S Certificates, the Class EC Distribution Account and proceeds thereof, shall constitute, and that the affairs of the Trust Fund (exclusive of the Lower-Tier REMIC and the Upper-Tier REMIC) shall be conducted so treated as to qualify such portion as, a “grantor trust” trust under subpart E, part I of subchapter J of the Code, and the provisions hereof shall be interpreted consistently with this intention. In furtherance of such intention, neither the Trustee nor the Certificate Administrator shall obtain a taxpayer identification number for the Grantor Trust on IRS Form SS-4 and shall furnish or cause to be furnished annually, and shall file or cause to be filed with the IRS together with Form 1041 or Form 1099 or such other Tax Return or form as may be applicable, to the Holders of the Class S Certificates, the amount of any Excess Interest received with respect to the Mortgage Loans. Under no circumstances shall the Certificate Administrator, the Trustee, the Master Servicer or the Special Servicer have the power to vary the investment of the Class EC and Class NR Certificateholders S Certificates in the Grantor Trust so as to take advantage of variations in the market rate of interest to improve their rate of return. If the Certificate Administrator determines that any Class S Certificate is held through a nominee, then the Grantor Trust will be treated as a WHFIT that is a WHMT. In such event, the Certificate Administrator shall report as required under the WHFIT Regulations, provided that the Certificate Administrator receives on a timely basis any and all information not already in its possession reasonably necessary for it to do so. The Certificate Administrator shall prepare or cause be entitled to rely on its determination that a Class S Certificate is held through a middleman and shall be preparedentitled to indemnification in accordance with the terms of this Agreement in the event that the IRS makes a determination that such determination is incorrect. As of the Closing Date, submit the Class S Certificates are not held through a nominee. The Certificate Administrator shall report required WHFIT information using the accrual method, except to the Trustee for execution (and extent the Trustee shall timely execute and timely return WHFIT Regulations specifically require a different method. The Certificate Administrator is under no obligation to determine whether the Holder of any Class S Certificate or other beneficial owner of a Class S Certificate, to the extent the Certificate Administrator) and timely file all Tax Returns in respect Administrator knows of any other beneficial owner of a Class S Certificate, uses the Grantor Trustcash or accrual method. The Certificate Administrator shall make available information as required by the WHFIT Regulations to such Holders of Class S Certificates annually. In addition, the Certificate Administrator is not responsible or liable for providing subsequently amended, revised or updated information to any Holder of any Class S Certificate unless requested by such Holder. The Certificate Administrator shall not be liable for failure to meet the reporting requirements of the WHFIT Regulations nor for any penalties thereunder (Awhich shall solely be the responsibility of the related Holders of Class S Certificates) fileif such failure is due to: (i) the lack of reasonably necessary information that is not in its possession being provided to the Certificate Administrator, or cause to be filed(ii) incomplete, Internal Revenue Service Form 1041 (or, in the event the Grantor Trust is a WHFIT, inaccurate or untimely information will be being provided on Form 1099) or such other form as may be applicable with the Internal Revenue Service with copies of the statements in the following clause and (B) furnish, or cause to be furnished, to the Class EC Certificate Administrator. Absent receipt of information regarding any sale of securities, including the price, amount of proceeds and Class NR Certificateholdersdate of sale from the beneficial owner thereof or the Depositor, their allocable share the Certificate Administrator shall assume there is no secondary market trading of income and expense with respect to WHFIT interests. To the Exchangeable Certificates and the Class EC Distribution Account, and the Excess Interest and Excess Interest Distribution Account, respectively, in the time or times and in the manner extent required by the CodeWHFIT Regulations, the Certificate Administrator shall use reasonable efforts to publish on an appropriate website the CUSIP Numbers for the Class S Certificates that represent ownership of a WHFIT. The Certificate Administrator shall make reasonable good faith efforts to keep the website accurate and updated to the extent CUSIP Numbers have been received. The Certificate Administrator is not liable for investor reporting delays that result from the receipt of inaccurate or untimely CUSIP Number information.

Grantor Trust Reporting. (a) The parties intend that the portions of the Trust Fund constituting the Grantor Trust, which consists of (i) the Excess Interest, the Excess Interest Account and proceeds thereof, and (ii) the uncertificated regular interests in the Upper-Tier REMIC represented by any Exchangeable Certificates that have been exchanged and converted for Class EC Certificates, the Class EC Distribution Account and proceeds thereof, shall constitute, and that the affairs of the Trust Fund (exclusive of the Lower-Tier REMIC and REMIC, the Upper-Tier REMIC and U-Haul Self Storage Trust Companion Loan REMIC) shall be conducted so as to qualify such portion as, a “grantor trust” under subpart E, part I of subchapter J of the Code, and the provisions hereof shall be interpreted consistently with this intention. In furtherance of such intention, neither the Trustee nor the Certificate Administrator shall have the power to vary the investment of the Class EC and Class NR Z Certificateholders in the Grantor Trust so as to improve their rate of return. The Certificate Administrator shall prepare or cause to be prepared, submit to the Trustee for execution (and the Trustee shall timely execute and timely return to the Certificate Administrator) and timely file all Tax Returns in respect of the Grantor Trust. In addition, the Certificate Administrator shall (A) file, or cause to be filed, Internal Revenue Service Form 1041 (or, in the event the Grantor Trust is a WHFIT, information will be provided on Form 1099) or such other form as may be applicable with the Internal Revenue Service with copies of the statements in the following clause and (B) furnish, or cause to be furnished, to the Class EC and Class NR Z Certificateholders, their allocable share of income and expense with respect to the Exchangeable Certificates and the Class EC Distribution Account, and the Excess Interest and Excess Interest Distribution Account, respectively, in the time or times and in the manner required by the Code.

Grantor Trust Reporting. (a) The parties intend that the portions portion of the Trust Fund constituting the Grantor Trust, which consists of (i) the Excess Class A-2SFL Regular Interest, the Excess Interest Account and proceeds thereof, and (ii) the uncertificated regular interests in the Upper-Tier REMIC represented by any Exchangeable Certificates that have been exchanged and converted for Class EC CertificatesA-3SFL Regular Interest, the Class EC Distribution Account Swap Contracts, the Floating Rate Accounts and proceeds thereof, shall constitute, and that the affairs of the Trust Fund (exclusive of the Lower-Tier REMIC, the Middle-Tier REMIC and the Upper-Tier REMIC) shall be conducted so as to qualify such portion as, a “"grantor trust” " under subpart E, part Part I of subchapter J of the Code, and the provisions hereof shall be interpreted consistently with this intention. In furtherance of such intention, neither the Trustee nor the Certificate Administrator shall have the no power to vary the investment of the Class EC A-2SFL and Class NR A-3SFL Certificateholders in the Grantor Trust their related assets so as to improve their rate of return. The Certificate Administrator In addition, the Paying Agent shall prepare (A) as soon as possible after the Swap Contracts are entered into (but no later than the first payment date under the Swap Contracts), obtain a taxpayer identification number for the Grantor Trust and deliver or cause to be prepared, submit to delivered the Trustee for execution (and the Trustee shall timely execute and timely return to the Certificate Administrator) and timely file all Tax Returns in respect federal taxpayer identification number of the Grantor Trust. In additionTrust on an IRS Form W-9 to each Swap Counterparty and, if requested by the Certificate Administrator shall Swap Counterparty (Aunless not permitted under federal income tax law), an applicable IRS Form W-8IMY, (B) file, or cause to be filed, Internal Revenue Service Form 1041 (or, in the event the Grantor Trust is a WHFIT, information will be provided on Form 1099) or such other form as may be applicable with the Internal Revenue Service with copies of the statements in the following clause clause, and (BC) furnish, or cause to be furnished, to the Class EC A-2SFL Certificateholders and the Class NR A-3SFL Certificateholders, their allocable share of income and expense with respect to the Exchangeable Certificates Class A-2SFL Regular Interest and the Class EC Distribution Account, A-3SFL Regular Interest and the Excess Interest and Excess Interest Distribution AccountSwap Contracts, respectively, each in the time or times and in the manner required by the Code.. [End of Article IV]

Grantor Trust Reporting. (a) The parties intend that the portions of the Trust Fund constituting consisting of the Grantor Trust, which consists of (i) right to receive all Excess Interest with respect to the Excess Interest, Mortgage Loans and related amounts held from time to time in the Excess Interest Account and proceeds thereofDistribution Account, and (ii) which will be beneficially owned by the uncertificated regular interests in Holders of the Upper-Tier REMIC represented by any Exchangeable Certificates that have been exchanged and converted for Class EC S Certificates, the Class EC Distribution Account and proceeds thereof, shall constitute, and that the affairs of the Trust Fund (exclusive of the Lower-Tier REMIC and the Upper-Tier REMIC) shall be conducted so treated as to qualify such portion as, a “grantor trust” trust under subpart E, part I of subchapter J of the Code, and the provisions hereof shall be interpreted consistently with this intention. In furtherance of such intention, neither the Trustee nor the Certificate Administrator shall furnish or cause to be furnished annually, and shall file or cause to be filed with the IRS together with Form 1041 or Form 1099 or such other Tax Return or form as may be applicable, to the Holders of [the Class [EC] Certificates and] the Class S Certificates, the amount of any Excess Interest received with respect to the Mortgage Loans. Under no circumstances shall the Certificate Administrator, the Trustee, the Master Servicer or the Special Servicer have the power to vary the investment of the [the Class EC and [EC] Certificates and] Class NR Certificateholders S Certificates in the Grantor Trust so as to take advantage of variations in the market rate of interest to improve their rate of return. The Grantor Trust is a WHFIT that is a WHMT. The Certificate Administrator shall prepare report as required under the WHFIT Regulations, provided that the Certificate Administrator receives on a timely basis any and all information not already in its possession reasonably necessary for it to do so. The Certificate Administrator is hereby directed to assume that the Class S Certificates are not held by a “middleman” (as such term is defined in the WHFIT Regulations) unless the Holder thereof or cause the Depositor provides the Certificate Administrator with the identity of any “middleman” that is the Holder of a Class S Certificate. The Certificate Administrator shall be entitled to rely on the first sentence of this paragraph and shall be preparedentitled to indemnification in accordance with the terms of this Agreement in the event that the IRS makes a determination that the first sentence of this paragraph is incorrect. The Certificate Administrator shall report required WHFIT information using the accrual method, submit except to the Trustee for execution (and extent the Trustee shall timely execute and timely return WHFIT Regulations specifically require a different method. The Certificate Administrator is under no obligation to determine whether the Holder of any Class S Certificate or other beneficial owner of a Class S Certificate, to the extent the Certificate Administrator) and timely file all Tax Returns in respect Administrator knows of any other beneficial owner of a Class S Certificate, uses the Grantor Trustcash or accrual method. The Certificate Administrator shall make available information as required by the WHFIT Regulations to such Holders of Class S Certificates annually. In addition, the Certificate Administrator is not responsible or liable for providing subsequently amended, revised or updated information to any Holder of any Class S Certificate unless requested by such Holder. The Certificate Administrator shall not be liable for failure to meet the reporting requirements of the WHFIT Regulations nor for any penalties thereunder (Awhich shall solely be the responsibility of the related Holders of Class S Certificates) fileif such failure is due to: (i) the lack of reasonably necessary information that is not in its possession being provided to the Certificate Administrator, or cause to be filed(ii) incomplete, Internal Revenue Service Form 1041 (or, in the event the Grantor Trust is a WHFIT, inaccurate or untimely information will be being provided on Form 1099) or such other form as may be applicable with the Internal Revenue Service with copies of the statements in the following clause and (B) furnish, or cause to be furnished, to the Class EC Certificate Administrator. Absent receipt of information regarding any sale of securities, including the price, amount of proceeds and Class NR Certificateholdersdate of sale from the beneficial owner thereof or the Depositor, their allocable share the Certificate Administrator shall assume there is no secondary market trading of income and expense with respect to WHFIT interests. To the Exchangeable Certificates and the Class EC Distribution Account, and the Excess Interest and Excess Interest Distribution Account, respectively, in the time or times and in the manner extent required by the CodeWHFIT Regulations, the Certificate Administrator shall use reasonable efforts to publish on an appropriate website the CUSIP Numbers for the Class S Certificates that represent ownership of a WHFIT. The Certificate Administrator shall make reasonable good faith efforts to keep the website accurate and updated to the extent CUSIP Numbers have been received. The Certificate Administrator is not liable for investor reporting delays that result from the receipt of inaccurate or untimely CUSIP Number information.]

Grantor Trust Reporting. (a) The parties intend that the portions of the Trust Fund constituting the Grantor Trust, which consists consisting of (i) the Excess InterestDefault Interest allocable to the Mortgage Loans, proceeds thereof held in the Excess Collection Account pertaining to the Default Interest Account allocable to the Mortgage Loans and proceeds thereofthe Default Interest Distribution Account, and (ii) the uncertificated regular interests Excess Interest allocable to the Mortgage Loans, proceeds thereof held in the Collection Account pertaining to the Excess Interest allocable to the Mortgage Loans and the Excess Interest Distribution Account, (iii) the Loan REMIC Residual Interest and proceeds thereof held in the Collection Account and the Lower-Tier Distribution Account pertaining to the Loan REMIC Residual Interests, and (iv) the Wilton Prepayment Premium Obligation and proceeds thereof held in the Collection Account, Lower-Tier Distribution Account or Upper-Tier REMIC represented by any Exchangeable Certificates that have been exchanged and converted for Class EC Certificates, the Class EC Distribution Account and proceeds thereof, pertaining thereto shall constitute, and that the affairs of the Trust Fund (exclusive of the Lower-Tier REMIC and the Upper-Tier REMICTrust REMICs) shall be conducted so as to qualify such portion as, as a “"grantor trust” " under subpart E, part I of subchapter J of the Code, and the provisions hereof shall be interpreted consistently with this intention. In furtherance of such intention, neither the Trustee nor the Certificate Bond Administrator shall have the power to vary the investment of the Class EC and Class NR Certificateholders in the Grantor Trust so as to improve their rate of return. The Certificate Administrator shall prepare furnish or cause to be prepared, submit furnished to Class Q-1 and Class Q-2 Certificateholders and to the Trustee for execution (and Holders of Certificates who receive the Trustee shall timely execute and timely return Prepayment Premium with respect to the Certificate Administrator) Wilton Prepayment Premium Obligation and timely shall file all Tax Returns in respect of the Grantor Trust. In addition, the Certificate Administrator shall (A) file, or cause to be filed, filed with the Internal Revenue Service together with Form 1041 (or, in the event the Grantor Trust is a WHFIT, information will be provided on Form 1099) or such other form as may be applicable with applicable, (x) the Internal Revenue Service with copies amount of Default Interest allocable to the Mortgage Loans received or accrued and the amount of any interest on unreimbursed Advances paid to the Servicer, the Special Servicer and/or the Trustee, as applicable, from Default Interest pursuant to Section 3.06(d)(iii) in the case of the statements Class Q-1 Certificates, (y) the amount of Excess Interest allocable to the Mortgage Loans received or accrued in the following clause case of the Class Q-2 Certificates, and (Bz) furnish, or cause to be furnished, to the Class EC and Class NR Certificateholders, their allocable share Classes of income and expense Certificates receiving a Prepayment Premium with respect to the Exchangeable Certificates and Wilton Prepayment Premium Obligation, the Class EC Distribution Accountamount thereof, and the Excess Interest and Excess Interest Distribution Account, respectively, in at the time or times and in the manner required by the Code; provided, that the Bond Administrator shall report to the Class LR Certificateholders with respect to the Loan REMIC Residual Interests in accordance with Section 4.02 and Section 4.04(b). The Trustee shall sign all Tax Returns and other reports required by this Section 4.07 promptly after receipt thereof from the Bond Administrator.

Grantor Trust Reporting. (a) The parties intend that the portions of the Trust Fund constituting the Grantor Trust, which consists consisting of (i) the AAPT Strip, the Default Interest, proceeds therefrom and the Class Q Distribution Account, (ii) Excess Interest, proceeds therefrom and the Excess Interest Account and proceeds thereof, and (ii) the uncertificated regular interests in the Upper-Tier REMIC represented by any Exchangeable Certificates that have been exchanged and converted for Class EC Certificates, the Class EC Distribution Account and (iii) the Montehiedra Partner Loans, proceeds thereoftherefrom, and the Class M Distribution Account shall constitute, and that the affairs of the Trust Fund (exclusive of the Lower-Tier REMIC and the Upper-Tier REMICTrust REMICs) shall be conducted so as to qualify such portion as, a “"grantor trust” " under subpart E, part I of subchapter J of the Code, and the provisions hereof shall be interpreted consistently with this intention. In furtherance of such intention, neither the Trustee nor the Certificate Administrator shall have the power to vary the investment of the Class EC and Class NR Certificateholders in the Grantor Trust so as to improve their rate of return. The Certificate Administrator shall prepare furnish or cause to be prepared, submit furnished to the Trustee for execution (Certificateholders and the Trustee shall timely execute and timely return to the Certificate Administrator) and timely file all Tax Returns in respect of the Grantor Trust. In addition, the Certificate Administrator shall (A) file, or cause to be filed, filed with the Internal Revenue Service together with Form 1041 (or, in the event the Grantor Trust is a WHFIT, information will be provided on Form 1099) or such other form as may be applicable with applicable, (i) to the Internal Revenue Service with copies Holders of the statements in the following clause and (B) furnishClass Q Certificates, or cause income with respect to be furnished, to the Class EC and Class NR Certificateholders, their allocable share of Default Interest and the amount of any interest paid on unreimbursed Advances to the Master Servicer, the Trustee and the Fiscal Agent, as applicable, therefrom pursuant to Section 3.06(iii) and the AAPT Strip at the time or times and in the manner required by the Code, (ii) to the Holders of the Classes of Regular Certificates entitled thereto as set forth in Section 2.06(b), income with respect to their allocable share of Excess Interest at the time or times and expense in the manner required by the Code, and (iii) to the Holders of the Class M Certificates, income with respect to their allocable share of the interest portion of any payments received on or with respect to the Exchangeable Certificates Montehiedra Partner Loans and any other income with respect to the Class EC Distribution AccountMontehiedra Partner Loans, and the Excess Interest and Excess Interest Distribution AccountServicing Fee or other expenses incurred by the Trust Fund with respect to the Class M Certificates, respectively, in at the time or times and in the manner required by the Code.

Grantor Trust Reporting. (a) The parties intend that the portions portion of the Trust Fund constituting the Grantor Trust, which consists of (i) the Excess Interest, the Excess Interest Distribution Account and proceeds thereof, thereof and (ii) the uncertificated regular interests in Class A-2FL/2FX Regular Interest, the Upper-Tier REMIC represented by any Exchangeable Certificates that have been exchanged and converted for Class EC CertificatesSwap Contract, the Class EC Distribution Account A-2FL/2FX Accounts and proceeds thereof, shall constitute, and that the affairs of the Trust Fund (exclusive of the Lower-Tier REMIC and the Upper-Tier REMIC) shall be conducted so as to qualify such portion as, a “grantor trust” under subpart E, part I of subchapter J of the Code, and the provisions hereof shall be interpreted consistently with this intention. In furtherance of such intention, neither the Trustee nor the Certificate Administrator shall have the power to vary the investment of the Class EC NR or the Class A-2FX and Class NR A-2FL Certificateholders in the Grantor Trust so as to improve their rate of return. The Certificate Administrator shall prepare or cause to be prepared, submit to the Trustee for execution (and the Trustee shall timely execute and timely return to the Certificate Administrator) and timely file all Tax Returns in respect of the Grantor Trust. In addition, the Certificate Administrator shall (A) as soon as possible after the Swap Contract is entered into (but no later than the first payment date under the Swap Contract), obtain a taxpayer identification number of the Grantor Trust and deliver or cause to be delivered the federal taxpayer identification number of the Grantor Trust on an Internal Revenue Service Form W-9 to the Swap Counterparty and, if requested by the Swap Counterparty (unless not permitted under federal income tax law), an applicable Internal Revenue Service Form W-8IMY; provided that Certificate Administrator shall not be responsible for failure to obtain a taxpayer identification number for the Grantor Trust if the Certificate Administrator timely takes all requisite action and such failure relates solely to a delay by the Internal Revenue Service in issuing such taxpayer identification number, (B) file, or cause to be filed, Internal Revenue Service Form 1041 (or, in the event the Grantor Trust is a WHFIT, information will be provided on Form 1099) or such other form as may be applicable with the Internal Revenue Service with copies of the statements in the following clause and (BC) furnish, or cause to be furnished, to the Class EC and Class NR Certificateholders, their allocable share of income and expense with respect to the Exchangeable Certificates and the Class EC Distribution Account, and the Excess Interest and Excess Interest Distribution Account, respectively, in the time or times and in the manner required by the Code, and (D) furnish, or cause to be furnished, to the Class A-2FX and Class A-2FL Certificateholders, their allocable share of income and expense with respect to the Class A-2FX Specific Grantor Trust Assets and the Class A-2FL Specific Grantor Trust Assets, respectively, each in the time or times and in the manner required by the Code.

Grantor Trust Reporting. (a) The parties intend that the portions portion of the Trust Fund constituting the Grantor Trust, which consists of (i) the Excess InterestInterest allocable to the Mortgage Loans, proceeds thereof held in the Certificate Account pertaining to the Excess Interest Account allocable to the Mortgage Loans and proceeds thereofthe Excess Interest Distribution Account, and (ii) the uncertificated regular interests in the Upper-Tier Loan REMIC represented by any Exchangeable Certificates that have been exchanged Residual Interests and converted for Class EC Certificates, the Class EC LR Distribution Account and proceeds thereof, (iii) the Prepayment Penalties and the Prepayment Penalty Distribution Accounts shall constitute, and that the affairs of the Trust Fund (exclusive of the Lower-Tier REMIC and the Upper-Tier REMIC) shall be conducted so as to qualify such portion as, a “"grantor trust” " under subpart E, part Part I of subchapter J of the Code, and the provisions hereof shall be interpreted consistently with this intention. In furtherance of such intention, neither the Trustee nor the Certificate Administrator shall have the no power to vary the investment of the Class EC and S, Class NR Certificateholders in the Grantor Trust so as to improve their rate of return. The Certificate Administrator shall prepare R, Class X-PP1 or cause to be prepared, submit to the Trustee for execution (and the Trustee shall timely execute and timely return to the Certificate Administrator) and timely file all Tax Returns in respect of the Grantor TrustClass X-PP2 Certificates. In addition, the Certificate Administrator Trustee shall (A) obtain a taxpayer identification number of the Grantor Trust; provided that Trustee shall not be responsible for failure to obtain a taxpayer identification number for the Grantor Trust if the Trustee timely takes all requisite action and such failure relates solely to a delay by the IRS in issuing such taxpayer identification number, (B) file, or cause to be filed, Internal Revenue Service Form 1041 (or, in the event the Grantor Trust is a WHFIT, information will be provided on Form 1099) or such other form as may be applicable with the Internal Revenue Service with copies of the statements in the following clause and (BC) furnish, or cause to be furnished, (i) to the Class EC and Class NR S Certificateholders, their allocable share of income and expense with respect to Excess Interest accrued or received, as applicable, (ii) to the Class LR Certificateholders, their allocable share of income with respect to the Exchangeable Certificates and Loan REMIC Residual Interests, (iii) to the Class EC Distribution AccountX-PP1 Certificateholders, their allocable share of income with respect to the PP1 Prepayment Penalties received and (iv) to the Class X-PP2 Certificateholders, their allocable share of income with respect to the PP2 Prepayment Penalties received. The Grantor Trust may be a WHFIT that is a WHMT. The Trustee will report as required under the WHFIT Regulations to the extent such information as is reasonably necessary to enable the Trustee to do so, and is not in its possession, is provided to the Excess Interest Trustee on a timely basis. Notwithstanding the foregoing, unless otherwise notified by the beneficial owner of a Class S, Class LR, Class X-PP1 or Class X-PP2 Certificate that such Certificate is registered in the name of a nominee or other middleman on behalf of such beneficial owner, the Trustee shall not treat the Grantor Trust as a WHFIT. The Trustee shall have no obligation to monitor whether the Grantor Trust has become a WHFIT following the Closing Date, and Excess Interest Distribution Accountshall be entitled to rely on the notification or absence thereof described in the preceding sentence and shall be entitled to indemnification in accordance with the terms of this Agreement in the event that the Internal Revenue Service makes a determination to the contrary. The Trustee, respectivelyin its discretion, shall report required WHFIT information using either the cash or accrual method, except to the extent the WHFIT Regulations specifically require a different method. The Trustee shall be under no obligation to determine whether any Certificateholder uses the cash or accrual method. The Trustee shall make available (via its website) WHFIT information to Certificateholders annually. In addition, the Trustee shall not be responsible or liable for providing subsequently amended, revised or updated information to any Certificateholder, unless requested by the Certificateholder. The Trustee shall not be liable for failure to meet the reporting requirements of the WHFIT Regulations nor for any penalties thereunder if such failure is due to: (i) the lack of reasonably necessary information being provided to the Trustee that is not in its possession, (ii) incomplete, inaccurate or untimely information being provided to the Trustee or (iii) the inability of the Trustee, after good faith efforts, to alter its existing information reporting systems to capture information necessary to fully comply with the WHFIT Regulations for the 2007 calendar year. Each owner of a class of securities representing, in whole or in part, beneficial ownership of an interest in a WHFIT, by acceptance of its interest in such class of securities, will be deemed to have agreed to provide the Trustee with information regarding any sale of such securities, including the price, amount of proceeds and date of sale. Absent receipt of information regarding any sale of Certificates, including the price, amount of proceeds and date of sale from the beneficial owner thereof or the Depositor, the Trustee shall assume there is no secondary market trading of WHFIT interests. To the extent required by the WHFIT Regulations, the Trustee shall use reasonable efforts to publish on an appropriate website the CUSIPs for the Certificates that represent ownership of a WHFIT. The CUSIPs so published will represent the Rule 144A CUSIPs. The Trustee shall make reasonable good faith efforts to keep the website accurate and updated to the extent CUSIPs have been received. Absent the receipt of a CUSIP, the Trustee will use a reasonable identifier number in lieu of a CUSIP. The Trustee shall not be liable for investor reporting delays that result from the receipt of inaccurate or untimely CUSIP information. The Trustee shall be entitled to additional reasonable compensation for changes in reporting required in respect of the WHFIT Regulations that arise as a result of a change in the WHFIT Regulations or a change in interpretation of the WHFIT Regulations by the IRS or the Depositor or its counsel, if such change requires, in the time or times and Trustee's sole discretion, a material increase in the manner required by Trustee's reporting obligations in respect of the Code.related Grantor Trust. [End of Article IV]

Grantor Trust Reporting. (a) The parties intend that the portions of the Trust Fund constituting consisting of the Grantor Trust, which consists of (i) Post-ARD Additional Interest and the Excess InterestPost-ARD Additional Interest Distribution Account, beneficially owned by the Excess Interest Account and proceeds thereof, Holders of the Class V Certificates and (ii) the uncertificated regular interests in the UpperClass A-Tier REMIC represented by any Exchangeable Certificates that have been exchanged and converted for Class EC CertificatesMFL Regular Interest, the Swap Agreement and the Floating Rate Account, beneficially owned by the Holders of the Class EC Distribution Account and proceeds thereof, A-MFL Certificates shall constitute, and that the affairs of such portions of the Trust Fund (exclusive of the Lower-Tier REMIC and the Upper-Tier REMIC) shall be conducted so as to qualify cause such portion as, portions to be treated as a “grantor trust” under subpart E, part I of subchapter J of the Code, and the provisions hereof shall be interpreted consistently with this intentionGrantor Trust. In furtherance of such intention, neither the Trustee nor the Certificate Administrator shall have the power agrees not to vary the investment of the Class EC and V Certificateholders or the Class NR A-MFL Certificateholders in the Grantor Trust so as with a view to taking advantage of fluctuations in market rates of interest to improve their rate rates of return. The Certificate Administrator In furtherance of such intention, the Trustee shall prepare furnish or cause to be prepared, submit furnished to the Trustee for execution (Class V Certificateholders and the Trustee shall timely execute Class A-MFL Certificateholders information returns with respect to income relating to their share of the related Post-ARD Additional Interest or income and timely return to the Certificate Administrator) and timely file all Tax Returns deductions in respect of the Grantor Trust. In additionClass A-MFL Regular Interest and the Swap Agreement, as applicable, and such other information as may be required pursuant to the Certificate Administrator Code, and shall (A) file, file or cause to be filed, filed with the Internal Revenue Service Service, such information returns, schedules and other information, together with Form 1041 (or, in the event the Grantor Trust is a WHFIT, information will be provided on Form 1099) or such other form as may be applicable with the Internal Revenue Service with copies of the statements in the following clause and (B) furnishapplicable, or cause to be furnished, to the Class EC and Class NR Certificateholders, their allocable share of income and expense with respect to the Exchangeable Certificates and the Class EC Distribution Account, and the Excess Interest and Excess Interest Distribution Account, respectively, in at the time or times and in the manner required by the Code. The Trustee shall deliver or cause to be delivered the federal taxpayer identification number of the Grantor Trust that holds the Swap Agreement on an IRS Form W-9 to the Swap Counterparty as soon as possible after such Swap Agreement is entered into (but no later than the first payment date under such Swap Agreement) and, if requested by the Swap Counterparty (unless not permitted under federal income tax law) an IRS Form W-8IMY. Each non-exempt Holder of Class A-MFL Certificates shall be obligated pursuant to this Agreement to provide applicable certification to the Trustee (with copies sent or faxed directly from such Certificateholder to the Swap Counterparty) to enable the Trustee to make payments to the Holders of the Class A-MFL Certificates without federal withholding or backup withholding. As authorized by the Holders of the Class A-MFL Certificates under this Agreement, the Trustee may forward any such certification received to the Swap Counterparty if requested. Without limiting the generality of the foregoing, the Depositor, within 10 days following the Trustee's request therefor, shall provide in writing to the Trustee such information as is reasonably requested by the Trustee for tax purposes and compliance with the administration and reporting duties under the Grantor Trust Provisions, and the Trustee's duty to perform its reporting and other tax compliance obligations under this Section 4.06 shall be subject to the condition that it receives from the Depositor such information possessed by the Depositor that is necessary to permit the Trustee to perform such obligations.