Initial Notional Amount. In addition to the principal described above, the Class R-1 and Class R-2 Certificates shall each be entitled to all distributions from their respective REMICs, if any, that are not otherwise provided for herein. The holders of the Class B-IO Certificates shall be treated for federal income tax purposes as entering into a notional principal contract with the Certificateholders entitled to receive Basis Risk Carry Forward Shortfall Amounts. For all federal tax purposes, Basis Risk Carry Forward Shortfall Amounts will be treated as transferred by a REMIC to the Class B-IO Certificates, which then transfer such amounts to the Classes entitled thereto pursuant to the notional principal contract. For federal tax return and information reporting, such notional principal contract shall be assigned a value of $100.
Appears in 2 contracts
Sources: Trust, Pooling and Servicing Agreement (Structured Asset Mortgage Investments Ii Inc), Trust, Pooling and Servicing Agreement (Thornburg Mortgage Inc)