Common use of REMIC Administration Clause in Contracts

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I, the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests and the interests represented by the Certificates.

REMIC Administration. (a) The An election will be made by the Certificate Administrator on behalf of the Trustee shall elect to treat each Trust REMIC the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Collection Account, the Reserve Accounts and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and, to the extent of the Trust’s interest therein, any related REO Properties as a REMIC under the Code and(such REMIC being herein designated as “REMIC I”), if necessary, under applicable state lawother than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Loan. Each such election Such elections will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC I I, and the REMIC I Residual Interest (which shall be evidenced by the Class R-I Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC I. The Class A CertificatesAn election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC II”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the Class M-1 Certificates and the Class M-2 Certificates REMIC II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC II II, and the REMIC II Residual Interest (which shall be evidenced by the Class R-II Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC II. The Class M-3 Certificates shall An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code (such REMIC being herein designated as Regular Interests “REMIC III”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Interests are issued. For purposes of such election, the Class A-0, Xxxxx X-0, Class A-SB, Class A-3, Class A-0, Xxxxx X-0, Class D, Class E, Class F, Class G and Class H Certificates, the EX XXXXX III Regular Interests, the Swap REMIC III Regular Interests, the Class J REMIC III Regular Interest and the Class R-X REMIC III Interest Regular Interests shall be designated as the “regular interests” in REMIC III, and the REMIC III Residual Interest (which shall be evidenced by the Class R Certificates) shall be designated as the sole class of “residual interests” in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Certificate Administrator shall not permit the creation of any "“interests" in any Trust REMIC ” (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Interests and the interests represented by the CertificatesREMIC III Interests.

REMIC Administration. (a) The An election will be made by the Certificate Administrator on behalf of the Trustee shall elect to treat each Trust REMIC the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Collection Account, the Reserve Accounts and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and, to the extent of the Trust’s interest therein, any related REO Properties as a REMIC under the Code and(such REMIC being herein designated as “REMIC I”), if necessary, under applicable state lawother than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Loan. Each such election Such elections will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC I I, and the REMIC I Residual Interest (which shall be evidenced by the Class R-I Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC I. The Class A CertificatesAn election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC II”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the Class M-1 Certificates and the Class M-2 Certificates REMIC II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC II II, and the REMIC II Residual Interest (which shall be evidenced by the Class R-II Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC II. The Class M-3 Certificates shall An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code (such REMIC being herein designated as Regular Interests “REMIC III”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Interests are issued. For purposes of such election, the Class A-0, Xxxxx X-0, Class A-SB, Class A-0, Xxxxx X-0, Class D, Class E, Class F and Class G Certificates, the EX XXXXX III Regular Interests, the Class H REMIC III Regular Interest and the Class R-X REMIC III Interest Regular Interests shall be designated as the “regular interests” in REMIC III, and the REMIC III Residual Interest (which shall be evidenced by the Class R Certificates) shall be designated as the sole class of “residual interests” in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Certificate Administrator shall not permit the creation of any "“interests" in any Trust REMIC ” (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Interests and the interests represented by the CertificatesREMIC III Interests.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I, the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates A Certificates, the Mezzanine Certificates, the Swap-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 CE Certificates shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interests Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "“interests" ” in any Trust REMIC (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Swap-IO Interest and the interests represented by the Certificates.

REMIC Administration. (a) The An election will be made by the Certificate Administrator on behalf of the Trustee shall elect to treat each Trust REMIC the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Collection Account, the Reserve Accounts and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and, to the extent of the Trust’s interest therein, any related REO Properties as a REMIC under the Code and(such REMIC being herein designated as “REMIC I”), if necessary, under applicable state lawother than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Loan. Each such election Such elections will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC I I, and the REMIC I Residual Interest (which shall be evidenced by the Class R-I Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC I. The Class A CertificatesAn election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC II”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the Class M-1 Certificates and the Class M-2 Certificates REMIC II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC II II, and the REMIC II Residual Interest (which shall be evidenced by the Class R-II Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC II. The Class M-3 Certificates shall An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code (such REMIC being herein designated as Regular Interests “REMIC III”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Interests are issued. For purposes of such election, the Class X-0, Xxxxx X-0, Class A-AB, Class X-0, Xxxxx X-0, Class D, Class E, Class F and Class G Certificates, the EC Trust REMIC III Regular Interests, the Class H REMIC III Regular Interest and the Class R-X REMIC III Interest Regular Interests shall be designated as the “regular interests” in REMIC III, and the REMIC III Residual Interest (which shall be evidenced by the Class R Certificates) shall be designated as the sole class of “residual interests” in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Certificate Administrator shall not permit the creation of any "“interests" in any Trust REMIC ” (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Interests and the interests represented by the CertificatesREMIC III Interests.

REMIC Administration. (a) The Trustee shall elect Pursuant to treat each Trust the 000 Xxxxxx Xxxxxx Pari Passu REMIC as a REMIC under the Code andDeclaration, if necessary, under applicable state law. Each such an election will be made by the Trustee to treat the segregated pool of assets consisting of the 000 Xxxxxx Xxxxxx Pari Passu Loan and all proceeds thereof or any real or personal property acquired with respect thereto as a REMIC (the "111 Eighth Avenue Pari Passu Loan REMIC") under the Code, other than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Mortgage Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on December 31, 2005. For purposes of such election, the 000 Xxxxxx Xxxxxx Pari Passu Loan REMIC Regular Interests shall each be designated as the Class of "regular interests" in the 000 Xxxxxx Xxxxxx Pari Passu Loan REMIC and the Class R-EA Certificates shall be designated as the sole Class of "residual interests" in the 000 Xxxxxx Xxxxxx Pari Passu Loan REMIC. An election will be made by the Trustee to treat the segregated pool of assets consisting of the Majority Mortgage Loans, the 000 Xxxxxx Xxxxxx Pari Passu Loan REMIC Regular Interest, such amounts related to the Majority Mortgage Loans as shall from time to time be held in the Certificate Account and the Interest Reserve Account, such amounts related to the Majority Mortgage Loans and the 000 Xxxxxx Xxxxxx Pari Passu Loan REMIC Regular Interest as shall from time to time be held in the Distribution Account, the related Insurance Policies and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Mortgage Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For purposes of such election, the REMIC I Regular Interests shall each be designated as a separate Class of "regular interests" in REMIC I and the REMIC I Residual Interest shall be designated as the sole Class of "residual interests" in REMIC I. An election will be made by the Trustee to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I II Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the Regular Interests "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole Class of the "residual interests" in REMIC II. The An election will be made by the Trustee to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class M-3 A-1, Class X-0, Xxxxx X-0, Class A-AB, Class A-4, Class A-J, Class X-1, Class X-2, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O, Class P and Class Q Certificates shall be designated as Regular Interests the "regular interests" in REMIC III and the Class R-III Interest Certificates shall be designated as the Residual Interest sole Class of "residual interests" in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the 000 Xxxxxx Xxxxxx Pari Passu Loan REMIC Regular Interest, REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests and the interests represented by the Residual Certificates.

REMIC Administration. (a) The An election will be made by the Certificate Administrator on behalf of the Trustee shall elect to treat each Trust REMIC the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Collection Account, the Reserve Accounts and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and, to the extent of the Trust’s interest therein, any related REO Properties as a REMIC under the Code and(such REMIC being herein designated as “REMIC I”), if necessary, under applicable state lawother than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Loan. Each such election Such elections will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC I I, and the REMIC I Residual Interest (which shall be evidenced by the Class R-I Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC I. The Class A CertificatesAn election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC II”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the Class M-1 Certificates and the Class M-2 Certificates REMIC II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC II II, and the REMIC II Residual Interest (which shall be evidenced by the Class R-II Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC II. The Class M-3 Certificates shall An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code (such 369 REMIC being herein designated as “REMIC III”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Interests are issued. For purposes of such election, the Class X-0, Xxxxx X-0, Class A-SB, Class A-3, Class X-0, Xxxxx X-0, Class D, Class E, Class F, Class G and Class H Certificates, the XX XXXXX III Regular Interests in REMIC III and the Class R-X REMIC III Interest Regular Interests shall be designated as the “regular interests” in REMIC III, and the REMIC III Residual Interest (which shall be evidenced by the Class R Certificates) shall be designated as the sole class of “residual interests” in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Certificate Administrator shall not permit the creation of any "“interests" in any Trust REMIC ” (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Interests and the interests represented by the CertificatesREMIC III Interests.

REMIC Administration. (a) The Trustee Certificate Administrator shall elect make elections or cause elections to be made to treat each of the Trust REMIC REMICs as a REMIC under the Code and, if necessary, under applicable state lawApplicable State and Local Tax Law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Uncertificated Regular Interests and the Certificates are issued. For the purposes of the REMIC election in respect of REMIC Ithe Upper-Tier REMIC, each Class of the REMIC I Regular Interests Certificates (exclusive of the portion of the Class NR Certificates representing an interest in the Grantor Trust) and the Class CSQ Certificates shall be designated as the Regular Interests “regular interests” (or in REMIC I the case of an exchange and conversion of Class A-S, Class B and Class C Certificates for Class EC Certificates, such “regular interests” shall be deemed to be held by the Trustee in uncertificated form unless reconverted to Class A-S, Class B and Class C Certificates) and the Class R-I UR Interest shall be designated as the Residual Interest sole class of “residual interests” in the Upper-Tier REMIC. For purposes of the REMIC I. The election in respect of the Lower-Tier REMIC, each Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates of Uncertificated Lower-Tier Interests shall be designated as the Regular Interests in REMIC II a class of “regular interests” and the Class R-II LR Interest shall be designated as the Residual Interest sole class of “residual interests” in the Lower-Tier REMIC. For purposes of the REMIC II. The election in respect of the Centreville Square Mortgage Loan REMIC, each Class M-3 Certificates of Uncertificated Centreville Square Interests shall be designated as Regular Interests in REMIC III a class of “regular interests” and the Class RCS-III R Interest shall be designated as the Residual Interest sole class of “residual interests” in REMIC IIIthe Centreville Square Mortgage Loan REMIC. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and None of the Class R-IV Interest shall be designated as Special Servicer, the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and Master Servicer nor the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "“interests" in any Trust REMIC ” (within the meaning of Section 860G of the Code) in any Trust REMIC other than the REMIC I Regular Interests and the interests represented by the Certificatesforegoing interests.

REMIC Administration. (a) The Trustee REMIC elections as set forth in the Preliminary Statement shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. The regular interests and residual interest in each REMIC shall be as designated in the Preliminary Statement. For the purposes of the REMIC election elections in respect of the Trust Fund, (i) the REMIC I1 Regular Interests will represent the “regular interests” in REMIC 1, the Class R-1 Interest will constitute the sole class of “residual interests” in REMIC I 1, (ii) the REMIC 2 Regular Interests shall be designated as will represent the Regular Interests “regular interests” in REMIC I 2, the Class R-2 Interest will constitute the sole class of “residual interests” in REMIC 2, (iii) the Class A Certificates, the Class M Certificates and the Class R-I C Certificates (exclusive of any right to receive distributions from the Net WAC Rate Carryover Reserve Account in respect of the Net WAC Rate Carryover Amount or the Swap Account or any obligation to make payments to the Swap Account), the Class IO Interest and the Class P Interest shall be designated as the Residual Interest “regular interests” in REMIC I. The Class A Certificates, the Class M-1 Certificates 3 and the Class M-2 Certificates shall be designated as R-3 Interest will constitute the Regular Interests sole class of “residual interests” in REMIC II 3, (iv) the Class C Certificates will represent ownership of “regular interests” in REMIC 4 and the Class R-4 Interest will constitute the sole class of “residual interests” in REMIC 4, (v) the Class P Certificates will represent ownership of “regular interests” in REMIC 5 and the Class R-5 Interest will constitute the sole class of “residual interests” in REMIC 5, (vi) the REMIC 6 Regular Interest SWAP IO will represent ownership of “regular interests” in REMIC 6 and the Class R-6 Interest will constitute the sole class of “residual interests” in REMIC 6, (vii) the Class R Certificates will evidence ownership of the Class R-1 Interest, Class R-2 Interest and Class R-3 Interest and (viii) the Class R-II X Certificates will evidence ownership of the Class R-4 Interest, the Class R-5 Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC IIIR-6 Interest. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Securities Administrator and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "“interests" in any Trust REMIC ” (within the meaning of Section 860G of the Code) in any REMIC created hereunder other than (a) the REMIC I 1 Regular Interests, the REMIC 2 Regular Interests, the REMIC 3 Regular Interests, the REMIC 4 Regular Interests, the REMIC 5 Regular Interests and or the interests REMIC 6 Regular Interests, the ownership of which is represented by the Class A and Class M Certificates., the SWAP IO, the Class C Certificates and the Class P Certificates and (b) the Class R-1 Interest, the Class R-2 Interest, the Class R-3 Interest, the Class R-4 Interest, the Class R-5 Interest and the Class R-6 Interest. The Securities Administrator will apply for an Employee Identification Number from the IRS via form SS-4 or any other acceptable method for each Trust REMIC

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Accounts, the Interest Reserve Account, the Distribution Account and the Reserve Account, the Insurance Policies and any related amounts REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the sole class of "residual interests" in REMIC I. An election will be made by the Trustee to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole class of the "residual interests" in REMIC II. The An election will be made by the Trustee to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class M-3 A-1, Class A-1A, Class A-2, Class A-3, Class A-4, Class A-1A, Class A-M, Class A-J, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O, Class P, Class X and Class X-Y Certificates shall be designated as Regular Interests the "regular interests" in REMIC III and the Class R-III Interest Certificates shall be designated as the Residual Interest sole class of "residual interests" in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests Interests, the REMIC II Regular Interests, the REMIC Regular Certificates and the interests represented by the Residual Certificates.

REMIC Administration. (a) The An election will be made by the Certificate Administrator on behalf of the Trustee shall elect to treat each Trust REMIC the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Collection Account, the Reserve Accounts and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and, to the extent of the Trust’s interest therein, any related REO Properties as a REMIC under the Code and(such REMIC being herein designated as “REMIC I”), if necessary, under applicable state lawother than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Loan. Each such election Such elections will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC I I, and the REMIC I Residual Interest (which shall be evidenced by the Class R-I Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC I. The Class A CertificatesAn election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC II”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the Class M-1 Certificates and the Class M-2 Certificates REMIC II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC II II, and the REMIC II Residual Interest (which shall be evidenced by the Class R-II Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC II. The Class M-3 Certificates shall An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC III”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Interests are issued. For purposes of such election, the Class X-0, Xxxxx X-0, Class A-SB, Class A-3, Class X-0, Xxxxx X-0, Class D, Class E, Class F, Class G and Class H Certificates, the XX XXXXX III Regular Interests in REMIC III and the Class R-X REMIC III Interest Regular Interests shall be designated as the “regular interests” in REMIC III, and the REMIC III Residual Interest (which shall be evidenced by the Class R Certificates) shall be designated as the sole class of “residual interests” in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Certificate Administrator shall not permit the creation of any "“interests" in any Trust REMIC ” (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Interests and the interests represented by the CertificatesREMIC III Interests.

REMIC Administration. (a) The An election will be made by the Certificate Administrator on behalf of the Trustee shall elect to treat each Trust REMIC the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Collection Account, the Reserve Accounts and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and, to the extent of the Trust’s interest therein, any related REO Properties as a REMIC under the Code and(such REMIC being herein designated as “REMIC I”), if necessary, under applicable state lawother than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Loan. Each such election Such elections will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC I I, and the REMIC I Residual Interest (which shall be evidenced by the Class R-I Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC I. The Class A CertificatesAn election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC II”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the Class M-1 Certificates and the Class M-2 Certificates REMIC II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC II II, and the REMIC II Residual Interest (which shall be evidenced by the Class R-II Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC II. The Class M-3 Certificates shall An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code (such REMIC being herein designated as Regular Interests “REMIC III”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Interests are issued. For purposes of such election, the Class A-1, Class A-2, Class A-3, Class A-4, Class A-S, Class B, Class C, Class D, Class E, Class F and Class G Certificates, the Class H REMIC III Regular Interest and the Class R-X REMIC III Interest Regular Interests shall be designated as the “regular interests” in REMIC III, and the REMIC III Residual Interest (which shall be evidenced by the Class R Certificates) shall be designated as the sole class of “residual interests” in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Certificate Administrator shall not permit the creation of any "“interests" in any Trust REMIC ” (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Interests and the interests represented by the CertificatesREMIC III Interests.

REMIC Administration. (a) The Trustee Certificate Administrator shall elect make elections or cause elections to be made to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state lawApplicable State and Local Tax Law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Uncertificated Lower-Tier Interests and the Certificates are issued. For the purposes of the REMIC election in respect of REMIC Ithe Upper-Tier REMIC, each Class of the REMIC I Regular Interests Certificates shall be designated as the Regular Interests “regular interests” (or in REMIC I the case of an exchange and conversion of Class A-S, Class B and Class C Certificates for Class EC Certificates, such “regular interests” shall be deemed to be held by the Trustee in uncertificated form unless reconverted to Class A-S, Class B and Class C Certificates) and the Class R-I UR Interest shall be designated as the Residual sole class of “residual interests” in the Upper-Tier REMIC. For purposes of the REMIC election in respect of the Lower-Tier REMIC, each Class of Uncertificated Lower-Tier Interests and the Subordinate Loan-Specific Certificates shall be designated as a class of “regular interests” and the Class LR Interest shall be designated as the sole class of “residual interests” in the Lower-Tier REMIC. For purposes of the REMIC I. The Class A Certificateselection in respect of the U-Haul Self Storage Pool 5 Trust Pari Passu Companion Loan REMIC, the Class M-1 Certificates and the Class M-2 UH5 Certificates shall be designated as the Regular Interests in REMIC II “regular interests” and an uncertificated interest represented by the Class R-II Interest R Certificates shall be designated as the Residual Interest sole class of “residual interests” in REMIC IIthe U-Haul Self Storage Pool 5 Trust Pari Passu Companion Loan REMIC. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and None of the Class R-III Interest shall be designated as Special Servicer, the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and Master Servicer nor the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "“interests" in any Trust REMIC ” (within the meaning of Section 860G of the Code) in any Trust REMIC other than the REMIC I Regular Interests and the interests represented by the Certificatesforegoing interests.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will shall be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I, (i) the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A CertificatesI, (ii) the Class M-1 Certificates and the Class M-2 Certificates REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates , (iii) the REMIC III Regular Interests shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The , (iv) the Class M-4 A Certificates, the Mezzanine Certificates (exclusive of the right to receive payments from the Net WAC Carryover Reserve Account or the Swap Account or the obligation to make payments to the Swap Account), the Class SWAP-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The , (v) the Class M-5 CE Certificates (exclusive of any obligation to make payments to the Net WAC Rate Carryover Reserve Account or the Swap Account) shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The V, (vi) the Class CE P Certificates shall be designated as the Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates VI and (vii) REMIC VII Regular Interest SWAP-IO shall be designated as the Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "“interests" ” in any Trust REMIC (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests Interests, the REMIC II Regular Interests, the REMIC III Regular Interests, the Class CE Interest, the Class P Interest, the Class SWAP-IO Interest and the interests represented by the Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Account, the Interest Reserve Account, the Distribution Account and the Reserve Account, the Insurance Policies and any related amounts REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to the Serviced Companion Loan. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the sole class of "residual interests" in REMIC I. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole class of the "residual interests" in REMIC II. The An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class M-3 Certificates A-1, Class A-2, Class A-3, Class A-4, Class A-5, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O, Class X-1 and Class X-2 Certificates, shall be designated as Regular Interests the "regular interests" in REMIC III and the Class R-III Interest Certificates shall be designated as the Residual Interest sole class of "residual interests" in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Paying Agent shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests Interests, the REMIC II Regular Interests, the REMIC III Regular Certificates and the interests represented by the Residual Certificates.

REMIC Administration. (a) The An election will be made by the Certificate Administrator on behalf of the Trustee shall elect to treat each Trust REMIC the segregated pool of assets consisting of the Mortgage Loans (other than any Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Collection Account, the Reserve Accounts and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and, to the extent of the Trust’s interest therein, any related REO Properties as a REMIC under the Code and(such REMIC being herein designated as “REMIC I”), if necessary, under applicable state lawother than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Loan. Each such election Such elections will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC I I, and the REMIC I Residual Interest (which shall be evidenced by the Class R-I Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC I. The Class A CertificatesAn election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC II”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the Class M-1 Certificates and the Class M-2 Certificates REMIC II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC II II, and the REMIC II Residual Interest (which shall be evidenced by the Class R-II Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC II. The Class M-3 Certificates shall An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code (such REMIC being herein designated as Regular Interests “REMIC III”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Interests are issued. For purposes of such election, the Class A-0, Xxxxx X-0, Class A-AB, Class A-0, Xxxxx X-0, Class D, Class E, Class F, Class G and Class H Certificates, the EX XXXXX III Regular Interests, the Class J REMIC III Regular Interest and the Class R-X REMIC III Interest Regular Interests shall be designated as the “regular interests” in REMIC III, and the REMIC III Residual Interest (which shall be evidenced by the Class R Certificates) shall be designated as the sole class of “residual interests” in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Certificate Administrator shall not permit the creation of any "“interests" in any Trust REMIC ” (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Interests and the interests represented by the CertificatesREMIC III Interests.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I, the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates REMIC III Regular Interests shall be designated as the Regular Interests in REMIC III and the Class R-III Interest interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates REMIC IV Regular Interests shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates REMIC V Regular Interests shall be designated as the Regular Interests in REMIC V and the Class R-V Interest interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates REMIC VI Regular Interests shall be designated as the Regular Interests in REMIC VI and the Class R-VI Interest interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates (other than the Residual Certificates) shall be designated as the Regular Interests in REMIC VII and the Class R-VII Interest interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "“interests" ” in any Trust REMIC created hereunder (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests, the REMIC II Regular Interests, REMIC III Regular Interests, REMIC IV Regular Interests, REMIC V Regular Interests, REMIC VI Regular Interests and REMIC VII Regular Interests and the interests represented by the Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I, the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A CertificatesFor the purposes of the REMIC election in respect of REMIC II, the Class M-1 Certificates and the Class M-2 Certificates REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 A Certificates and the Mezzanine Certificates (other than the right to receive amounts from the Net WAC Rate Carryover Reserve Account or the Swap Account or the obligation to make payments to the Swap Account), the Class CE-1 Interest, the Class CE-2 Interest, the Class P Interest and the Class Swap-IO Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 CE-1 Certificates shall be designated as the Regular Interests Interest in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 P Certificates shall be designated as the Regular Interests Interest in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates REMIC VI Regular Interest Swap-IO shall be designated as the Regular Interests Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P CE-2 Certificates shall be designated as the Regular Interests Interest in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "“interests" ” in any Trust REMIC (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests and the interests represented by the Certificates.

REMIC Administration. (a) The An election will be made by the Certificate Administrator on behalf of the Trustee shall elect to treat each Trust REMIC the segregated pool of assets consisting of the Mortgage Loans (other than 367 Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Collection Account, the Reserve Accounts and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and, to the extent of the Trust’s interest therein, any related REO Properties as a REMIC under the Code and(such REMIC being herein designated as “REMIC I”), if necessary, under applicable state lawother than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Loan. Each such election Such elections will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC I I, and the REMIC I Residual Interest (which shall be evidenced by the Class R-I Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC I. The Class A CertificatesAn election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC II”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the Class M-1 Certificates and the Class M-2 Certificates REMIC II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC II II, and the REMIC II Residual Interest (which shall be evidenced by the Class R-II Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC II. The Class M-3 Certificates shall An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code (such REMIC being herein designated as Regular Interests “REMIC III”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Interests are issued. For purposes of such election, the Class A-0, Xxxxx X-0, Class A-SB, Class A-0, Xxxxx X-0, Class D, Class E, Class F and Class G Certificates, the EX XXXXX III Regular Interests, the Class H REMIC III Regular Interest and the Class R-X REMIC III Interest Regular Interests shall be designated as the “regular interests” in REMIC III, and the REMIC III Residual Interest (which shall be evidenced by the Class R Certificates) shall be designated as the sole class of “residual interests” in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Certificate Administrator shall not permit the creation of any "“interests" in any Trust REMIC ” (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Interests and the interests represented by the CertificatesREMIC III Interests.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Account, the Interest Reserve Account, the Reserve Account and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Mortgage Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the sole Class of "residual interests" in REMIC I. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class R-II Certificates shall be designated as the sole Class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates and Class A-4FL Certificates are issued. For purposes of such election, the Class A-1, Class A-2, Class A-3, Class A-AB, Class A-4, Class A-J, Class X, Class B, Claxx X, Xxxxx X, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O and Class P Certificates (but other than the Class P Grantor Trust Interest) and the Class A-4FL Regular Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests "regular interests" in REMIC III and the Class R-III Interest Certificates shall be designated as the Residual Interest sole Class of "residual interests" in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Paying Agent shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Majority Mortgage Loans, the Mall at Millenia Pari Passu Loan REMIC Regular Interest, such amounts related to the Majority Mortgage Loans as shall from time to time be held in the Certificate Account and the Interest Reserve Account, such amounts related to the Majority Mortgage Loans and the Mall at Millenia Pari Passu Loan REMIC Regular Interest as shall from time to time be held in the Distribution Account, the related Insurance Policies and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Mortgage Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-REMIC I Residual Interest shall be designated as the Residual Interest sole Class of "residual interests" in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests and the interests represented Residual Certificates. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class R-II Certificates shall be designated as the sole Class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class A-1, Class A-2, Class A-3, Class A-4, Class A-5, Class A-6, Class A-7, Class X-1, Class X-2, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O, Class P and Class Q Certificates shall be designated as the "regular interests" in REMIC III and the Class R-III Certificates shall be designated as the sole Class of "residual interests" in REMIC III. The Paying Agent shall not permit the creation of any "interests" (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the Mall at Millenia Pari Passu Loan REMIC Regular Interest, REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests and the Residual Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will shall be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I, (i) the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A CertificatesI, (ii) the Class M-1 Certificates and the Class M-2 Certificates REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The , (iii) the Class M-3 A Certificates, the Mezzanine Certificates (exclusive of the right to receive payments from the Net WAC Carryover Reserve Account or the Swap Account or the obligation to make payments to the Swap Account), the Class SWAP-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The , (v) the Class M-4 CE Certificates shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The , (vi) the Class M-5 P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates V and (vii) REMIC VI Regular Interest SWAP-IO shall be designated as the Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "“interests" ” in any Trust REMIC (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests Interests, the REMIC II Regular Interests, the Class CE Interest, the Class P Interest, the Class SWAP-IO Interest and the interests represented by the Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I, the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A CertificatesFor the purposes of the REMIC election in respect of REMIC II, the Class M-1 Certificates and the Class M-2 Certificates REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 A Certificates and the Mezzanine Certificates (other than the right to receive amounts from the Net WAC Rate Carryover Reserve Account or the Swap Account or the obligation to make payments to the Swap Account), the Class CE-1 Interest, the Class CE-2 Interest, the Class P Interest and the Class Swap-IO Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 CE-1 Certificates shall be designated as the Regular Interests Interest in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 P Certificates shall be designated as the Regular Interests Interest in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates REMIC VI Regular Interest Swap-IO shall be designated as the Regular Interests Interest in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P CE-2 Certificates shall be designated as the Regular Interests Interest in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests and the interests represented by the Certificates.

REMIC Administration. (a) The Trustee Paying Agent shall elect make elections or cause elections to be made to treat each Trust of the Loan REMIC, the Lower-Tier REMIC and the Upper-Tier REMIC as a REMIC under the Code and, if necessary, under applicable state lawApplicable State and Local Tax Law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Uncertificated Lower-Tier Interests and the Certificates are issued. For the purposes of the REMIC election in respect of REMIC Ithe Upper-Tier REMIC, each Class of the Regular Certificates and the Class PS Certificates shall be designated as the "regular interests" (in the case of the Class NR Certificates, exclusive of the portion thereof, representing the right to Excess Interest and Amounts in the Excess Interest Distribution Account) and the Class R Certificates shall be designated as the sole class of "residual interests" in the Upper-Tier REMIC. For purposes of the REMIC I election in respect of the Lower-Tier REMIC, each Class of Uncertificated Lower-Tier Interests shall be designated as the "regular interests" and the Class LR Certificates shall be designated as the sole class of "residual interests" in the Lower-Tier REMIC. For purposes of the REMIC election in respect of the Loan REMIC, each Class of Loan REMIC Regular Interests shall be designated as the Regular Interests in REMIC I "regular interests" and the Loan REMIC Residual Interest, represented by the Class R-I Interest LR Certificates, shall be designated as the Residual Interest sole class of "residual interests" in REMIC I. The Class A Certificatesthe Loan REMIC. None of the Special Servicer, the Class M-1 Certificates and Servicer, the Class M-2 Certificates shall be designated as Paying Agent nor the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in the Loan REMIC, the Lower-Tier REMIC or the Upper-Tier REMIC other than the REMIC I Regular Interests and the interests represented by the Certificatesforegoing interests.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Each such Such election will be made by the Trust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I-A, the REMIC I I-A Regular Interests shall be designated as the Regular Interests in REMIC I I-A and the Class R-IA Interest shall be designated as the Residual Interests in REMIC I-A. For the purposes of the REMIC election in respect of REMIC I-B, the Group I Certificates (other than the Class I-R Certificates) shall be designated as the Regular Interests in REMIC I-B and the Class R-IB Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, I-B. Neither the Class M-1 Certificates and Trustee nor the Class M-2 Certificates Trust Administrator shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "“interests" ” in any Trust REMIC I-A or REMIC I-B (within the meaning of Section 860G of the Code) other than the REMIC I I-A Regular Interests and the interests represented Group I Certificates. For the purposes of the REMIC election in respect of REMIC II, the REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class II-R Certificates shall be designated as the Residual Interests in REMIC II. Neither the Trustee nor the Trust Administrator shall permit the creation of any “interests” in REMIC II (within the meaning of Section 860G of the Code) other than the REMIC II Regular Interests and the Group II Certificates. The Trustee shall elect to treat each REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Such election will be made by the CertificatesTrust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued.

REMIC Administration. (a) The Trustee Trust Administrator shall elect to treat each Trust REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Each such Such election will be made by the Trust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I, the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Floating Rate Certificates (exclusive of any right to receive distributions from or obligation to make payments to the Net WAC Rate Carryover Reserve Account in respect of the Net WAC Rate Carryover Amount or the Swap Account), the Class M-3 Certificates CE Interest, the Class IO Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 CE Certificates (exclusive of any right to receive distributions from or obligation to make payments to the Net WAC Rate Carryover Reserve Account in respect of the Net WAC Rate Carryover Amount or the Swap Account) shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates REMIC VI Regular Interest SWAP IO shall be designated as the Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates Neither the Trustee nor the Trust Administrator shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "“interests" ” in any Trust REMIC (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests and the interests represented by the Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account, the Insurance Policies and any REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note and Companion Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the Regular Interests sole Class of "residual interests" in REMIC II I. The Trustee and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Paying Agent shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests and the interests represented Residual Certificates. An election will be made by the CertificatesPaying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class R-II Certificates shall be designated as the sole Class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class A-1, Class A-2, Class X-1 (each Class X-1 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class X-2 (each Class X-2 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N and Class O Certificates shall be designated as the "regular interests" in REMIC III and the Class R-III Certificates shall be designated as the sole Class of "residual interests" in REMIC III.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I, the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates Certificates, the Class M-2 Interest, the Class M-3 Interest, the Class M-4 Interest, the Class M-5 Interest, the Class CE Interest and the Class M-2 Certificates P Interest shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 M-2 Certificates shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 M-3 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P M-4 Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class M-5 Certificates shall be designated as the Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class CE Certificates shall be designated as the Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Class P Certificates shall be designated as the Regular Interests in REMIC VIII and the Class R-VIII Interest shall be designated as the Residual Interest in REMIC VIII. The Trustee shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests and the interests represented by the Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Accounts, the Interest Reserve Account, the Distribution Account and the Reserve Account, the Insurance Policies and any related amounts REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing allocable to a Serviced Companion Loan. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the sole class of "residual interests" in REMIC I. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class R-II Certificates shall be designated as the sole class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates and the Class A-MFL Regular Interest are issued. For purposes of such election, the Class A-1, Class A-1A, Class A-2, Class A-NM, Class A-3, Class A-AB, Class A-4, Class A-1A, Class A-M, Class A-J, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O, Class P, Class Q, Class S, Class X-1, Class X-2 and Class X-W Certificates and the Class A-MFL Regular Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests "regular interests" in REMIC III and the Class R-III Interest Certificates shall be designated as the Residual Interest sole class of "residual interests" in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Paying Agent shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests Interests, the REMIC II Regular Interests, the REMIC Regular Certificates, the Class A-MFL Regular Interest and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee shall elect make elections or cause elections to be made to treat each Trust of the Lower-Tier REMIC, the Middle-Tier REMIC and the Upper-Tier REMIC as a REMIC under the Code and, if necessary, under applicable state lawApplicable State and Local Tax Law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Uncertificated Lower-Tier Interests, Uncertificated Middle-Tier Interests and the Certificates are issued. For the purposes of the REMIC election in respect of REMIC Ithe Upper-Tier REMIC, each Class of the Regular Certificates (other than the Class A-2SFL Certificates and the Class A-JFL Certificates) and the Class A-2SFL Regular Interest and the Class A-JFL Regular Interest shall be designated as the "regular interests" and the Class R Certificates shall be designated as the sole class of "residual interests" in the Upper-Tier REMIC. For purposes of the REMIC I Regular election in respect of the Middle-Tier REMIC, each Class of Uncertificated Middle-Tier Interests shall be designated as the Regular Interests in REMIC I "regular interests" and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 MR Certificates shall be designated as the Regular sole class of "residual interests" in the Middle-Tier REMIC. For purposes of the REMIC election in respect of the Lower-Tier REMIC, each Class of Uncertificated Lower-Tier Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The "regular interests" and the Class M-3 LR Certificates shall be designated as Regular Interests the sole class of "residual interests" in REMIC III and the Class RLower-III Interest shall be designated as Tier REMIC. None of the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and Special Servicer, the Class R-IV Interest shall be designated as Master Servicers nor the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in the Lower-Tier REMIC, the Middle-Tier REMIC or the Upper-Tier REMIC other than the REMIC I Regular Interests and the interests represented by the Certificatesforegoing interests.

REMIC Administration. (a) The Trustee Paying Agent shall elect make elections or cause elections to be made to treat each Trust of the Lower-Tier REMIC, the Middle-Tier REMIC and the Upper-Tier REMIC as a REMIC under the Code and, if necessary, under applicable state lawApplicable State and Local Tax Law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Uncertificated Lower-Tier Interests, Uncertificated Middle-Tier Interests and the Certificates are issued. For the purposes of the REMIC election in respect of REMIC Ithe Upper-Tier REMIC, each Class of the Regular Certificates (other than the Class A-2SFL Certificates and the Class A-3SFL Certificates) and the Class A-2SFL Regular Interest and the Class A-3SFL Regular Interest shall be designated as the "regular interests" and the Class R Certificates shall be designated as the sole class of "residual interests" in the Upper-Tier REMIC. For purposes of the REMIC I Regular election in respect of the Middle-Tier REMIC, each Class of Uncertificated Middle-Tier Interests shall be designated as the Regular Interests in REMIC I "regular interests" and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 MR Certificates shall be designated as the Regular sole class of "residual interests" in the Middle-Tier REMIC. For purposes of the REMIC election in respect of the Lower-Tier REMIC, each Class of Uncertificated Lower-Tier Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The "regular interests" and the Class M-3 LR Certificates shall be designated as Regular Interests the sole class of "residual interests" in REMIC III and the Class RLower-III Interest shall be designated as Tier REMIC. None of the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and Special Servicer, the Class R-IV Interest shall be designated as Master Servicers, the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and Paying Agent nor the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in the Lower-Tier REMIC, the Middle-Tier REMIC or the Upper-Tier REMIC other than the REMIC I Regular Interests and the interests represented by the Certificatesforegoing interests.

REMIC Administration. (a) The An election will be made by the Certificate Administrator on behalf of the Trustee shall elect to treat each Trust REMIC the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Collection Account, the Reserve Accounts and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and, to the extent of the Trust’s interest therein, any related REO Properties as a REMIC under the Code and(such REMIC being herein designated as “REMIC I”), if necessary, under applicable state lawother than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Loan. Each such election Such elections will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC I I, and the REMIC I Residual Interest (which shall be evidenced by the Class R-I Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC I. The Class A CertificatesAn election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC II”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the Class M-1 Certificates and the Class M-2 Certificates REMIC II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC II II, and the REMIC II Residual Interest (which shall be evidenced by the Class R-II Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC II. The Class M-3 Certificates shall An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC III”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Interests are issued. For purposes of such election, the Class A-1, Class A-2, Class A-0, Xxxxx X-0, Class D, Class E, Class F, Class G and Class H Certificates, the Class J REMIC III Regular Interest, the Class PST REMIC III Regular Interests in REMIC III and the Class R-X REMIC III Interest Regular Interests shall be designated as the “regular interests” in REMIC III, and the REMIC III Residual Interest (which shall be evidenced by the Class R Certificates) shall be designated as the sole class of “residual interests” in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Certificate Administrator shall not permit the creation of any "“interests" in any Trust REMIC ” (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Interests and the interests represented by the CertificatesREMIC III Interests.

REMIC Administration. (a) The An election will be made by the Certificate Administrator on behalf of the Trustee shall elect to treat each Trust REMIC the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Collection Account, the Reserve Accounts and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and, to the extent of the Trust’s interest therein, any related REO Properties as a REMIC under the Code and(such REMIC being herein designated as “REMIC I”), if necessary, under applicable state lawother than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Loan. Each such election Such elections will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC I I, and the REMIC I Residual Interest (which shall be evidenced by the Class R-I Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC I. The Class A CertificatesAn election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC II”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the Class M-1 Certificates and the Class M-2 Certificates REMIC II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC II II, and the REMIC II Residual Interest (which shall be evidenced by the Class R-II Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC II. The Class M-3 Certificates shall An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code (such REMIC being herein designated as Regular Interests “REMIC III”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Interests are issued. For purposes of such election, the Class A-1, Class A-2, Class A-3, Class A-4, Class A-J, Class B, Class C, Class D, Class E, Class F and Class G Certificates, the Class H REMIC III Regular Interest and the Class R-X REMIC III Interest Regular Interests shall be designated as the “regular interests” in REMIC III, and the REMIC III Residual Interest (which shall be evidenced by the Class R Certificates) shall be designated as the sole class of “residual interests” in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Certificate Administrator shall not permit the creation of any "“interests" in any Trust REMIC ” (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Interests and the interests represented by the CertificatesREMIC III Interests.

REMIC Administration. (a) The An election will be made by the Certificate Administrator on behalf of the Trustee shall elect to treat each Trust REMIC the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Collection Account, the Reserve Accounts and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and, to the extent of the Trust’s interest therein, any related REO Properties as a REMIC under the Code and(such REMIC being herein designated as “REMIC I”), if necessary, under applicable state lawother than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Loan. Each such election Such elections will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC I I, and the REMIC I Residual Interest (which shall be evidenced by the Class R-I Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC I. The Class A CertificatesAn election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC II”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the Class M-1 Certificates and the Class M-2 Certificates REMIC II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC II II, and the REMIC II Residual Interest (which shall be evidenced by the Class R-II Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC II. The Class M-3 Certificates shall An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC III”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Interests are issued. For purposes of such election, the Class X-0, Xxxxx X-0, Class A-SB, Class X-0, Xxxxx X-0, Class D, Class E, Class F, Class G, Class H and Class J Certificates, the XX XXXXX III Regular Interests in REMIC III and the Class R-X REMIC III Interest Regular Interests shall be designated as the “regular interests” in REMIC III, and the REMIC III Residual Interest (which shall be evidenced by the Class R Certificates) shall be designated as the sole class of “residual interests” in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Certificate Administrator shall not permit the creation of any "“interests" in any Trust REMIC ” (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Interests and the interests represented by the CertificatesREMIC III Interests.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Each such Such election will be made by the Trust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I-A, the REMIC I I-A Regular Interests shall be designated as the Regular Interests in REMIC I I-A and the Class R-I IA Residual Interest shall be designated as the Residual Interests in REMIC I-A. For the purposes of the REMIC election in respect of REMIC I-B, the REMIC I-B Regular Interests shall be designated as the Regular Interests in REMIC I-B and the Class R-IB Residual Interest shall be designated as the Residual Interests in REMIC I-B. For the purposes of the REMIC election in respect of REMIC I-C, the Group 1 Certificates or Components thereof (other than the Class 1-R Certificates), shall be designated as the Regular Interests in REMIC I-C and the Class R-IC Residual Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, I-C. Neither the Class M-1 Certificates and Trustee nor the Class M-2 Certificates Trust Administrator shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "“interests" ” in any Trust REMIC I-A, REMIC I-B or REMIC I-C (within the meaning of Section 860G of the Code) other than the REMIC I I-A Regular Interests, REMIC I-B Regular Interests and the interests represented Group 1 Certificates. For the purposes of the REMIC election in respect of REMIC II-A, the REMIC II-A Regular Interests shall be designated as the Regular Interests in REMIC II-A and the Class R-IIA Residual Interest shall be designated as the Residual Interests in REMIC II-A. For the purposes of the REMIC election in respect of REMIC II-B, the REMIC II-B Regular Interests shall be designated as the Regular Interests in REMIC II-B and the Class R-IIB Residual Interest shall be designated as the Residual Interests in REMIC II-B. For the purposes of the REMIC election in respect of REMIC II-C, the Group 1 Certificates or Components thereof (other than the Class 2-R Certificates), shall be designated as the Regular Interests in REMIC II-C and the Class R-IIC Residual Interest shall be designated as the Residual Interest in REMIC II-C. Neither the Trustee nor the Trust Administrator shall permit the creation of any “interests” in REMIC II-A, REMIC II-B or REMIC II-C (within the meaning of Section 860G of the Code) other than the REMIC II-A Regular Interests, the REMIC II-B Regular Interests and the Group 2 Certificates. The Trustee shall elect to treat each REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Such election will be made by the CertificatesTrust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued.

REMIC Administration. (a) The Trustee REMIC elections as set forth in the Preliminary Statement shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. The regular interests and residual interest in each REMIC shall be as designated in the Preliminary Statement. For the purposes of the REMIC election elections in respect of the Trust Fund, (i) the REMIC I1 Regular Interests will represent the “regular interests” in REMIC 1, the Class R-1 Interest will constitute the sole class of “residual interests” in REMIC I 1, (ii) the REMIC 2 Regular Interests shall be designated as will represent the “regular interests” in REMIC 2, the Class R-2 Interest will constitute the sole class of “residual interests” in REMIC 2, (iii) the REMIC 3 Regular Interests will represent the “regular interests” in REMIC I 3, the Class R-3 Interest will constitute the sole class of “residual interests” in REMIC 3, (iv) the Class A Certificates, the Class M Certificates (exclusive of any right to receive distributions from the Net WAC Rate Carryover Reserve Account in respect of the Net WAC Rate Carryover Amount or the Swap Account or any obligation to make payments to the Swap Account), the Class C Interest, the Class IO Interest and the Class R-I P Interest shall be designated as the Residual Interest “regular interests” in REMIC I. The Class A Certificates, the Class M-1 Certificates 4 and the Class M-2 Certificates shall be designated as R-4 Interest will constitute the Regular Interests sole class of “residual interests” in REMIC II 4, (v) the Class C Certificates (exclusive of any obligation to make payments to the Net WAC Rate Carryover Reserve Account in respect of the Net WAC Rate Carryover Amount) will represent ownership of “regular interests” in REMIC 5 and the Class R-5 Interest will constitute the sole class of “residual interests” in REMIC 5, (vi) the Class P Certificates will represent ownership of “regular interests” in REMIC 6 and the Class R-6 Interest will constitute the sole class of “residual interests” in REMIC 6, (vii) the REMIC 7 Regular Interest SWAP IO will represent ownership of “regular interests” in REMIC 7 and the Class R-7 Interest will constitute the sole class of “residual interests” in REMIC 7, (viii) the Class R Certificates will evidence ownership of the Class R-2 Interest, Class R-3 Interest and Class R-4 Interest and (ix) the Class R-II X Certificates will evidence ownership of the Class R-5 Interest, the Class R-6 Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC IIIR-7 Interest. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Securities Administrator and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "“interests" in any Trust REMIC ” (within the meaning of Section 860G of the Code) in any REMIC created hereunder other than (a) the REMIC I 1 Regular Interests, the REMIC 2 Regular Interests, the REMIC 3 Regular Interests, the REMIC 4 Regular Interests, the REMIC 5 Regular Interests, the REMIC 6 Regular Interests and or the interests REMIC 7 Regular Interests, the ownership of which is represented by the Class A Certificates., the Class M Certificates, the REMIC 7 Regular Interest SWAP IO, the Class C Certificates and the Class P Certificates and (b) the Class R-2 Interest, the Class R-3 Interest, the Class R-4 Interest, the Class R-5 Interest, the Class R-6 Interest and the Class R-7 Interest. The Securities Administrator will apply for an Employee Identification Number from the IRS via form SS-4 or any other acceptable method for each Trust REMIC

REMIC Administration. (a) The An election will be made by the Certificate Administrator on behalf of the Trustee shall elect to treat each Trust REMIC the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Collection Account, the Reserve Accounts and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and, to the extent of the Trust’s interest therein, any related REO Properties as a REMIC under the Code and(such REMIC being herein designated as “REMIC I”), if necessary, under applicable state lawother than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Loan. Each such election Such elections will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC I I, and the REMIC I Residual Interest (which shall be evidenced by the Class R-I Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC I. The Class A CertificatesAn election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC II”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the Class M-1 Certificates and the Class M-2 Certificates REMIC II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC II II, and the REMIC II Residual Interest (which shall be evidenced by the Class R-II Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC II. The Class M-3 Certificates shall An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code (such REMIC being herein designated as Regular Interests “REMIC III”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Interests are issued. For purposes of such election, the Class A-1, Class A-2, Class A-3, Xxxxx X-0, Xlass D, Class E, Class F, Class G and Class H Certificates, the EC Trust REMIC III Regular Interests, the Class J REMIC III Regular Interest and the Class R-X REMIC III Interest Regular Interests shall be designated as the “regular interests” in REMIC III, and the REMIC III Residual Interest (which shall be evidenced by the Class R Certificates) shall be designated as the sole class of “residual interests” in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Certificate Administrator shall not permit the creation of any "“interests" in any Trust REMIC ” (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Interests and the interests represented by the CertificatesREMIC III Interests.

REMIC Administration. (a) The Trustee Certificate Administrator shall elect make elections or cause elections to be made to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state lawApplicable State and Local Tax Law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Uncertificated Lower-Tier Interests and the Certificates are issued. For the purposes of the REMIC election in respect of REMIC Ithe Upper-Tier REMIC, each Class of the REMIC I Regular Interests Certificates shall be designated as the Regular Interests “regular interests” (or in REMIC I the case of an exchange and conversion of Class A-S, Class B and Class C Certificates for Class EC Certificates, such “regular interests” shall be deemed to be held by the Trustee in uncertificated form unless reconverted to Class A-S, Class B and Class C Certificates) and the Class R-I UR Interest shall be designated as the Residual sole class of “residual interests” in the Upper-Tier REMIC. For purposes of the REMIC election in respect of the Lower-Tier REMIC, each Class of Uncertificated Lower-Tier Interests shall be designated as a class of “regular interests” and the Class LR Interest shall be designated as the sole class of “residual interests” in the Lower-Tier REMIC. For purposes of the REMIC I. The Class A Certificateselection in respect of the U-Haul Self Storage Trust Companion Loan REMIC, the Class M-1 Certificates and the Class M-2 UHP Certificates shall be designated as the Regular Interests in REMIC II “regular interests” and an uncertificated interest represented by the Class R-II Interest R Certificates shall be designated as the Residual Interest sole class of “residual interests” in REMIC IIthe U-Haul Self Storage Trust Companion Loan REMIC. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and None of the Class R-III Interest shall be designated as Special Servicer, the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and Master Servicer nor the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "“interests" in any Trust REMIC ” (within the meaning of Section 860G of the Code) in any Trust REMIC other than the REMIC I Regular Interests and the interests represented by the Certificatesforegoing interests.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in a Certificate Account, the Reserve Account, the Interest Reserve Account and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Mortgage Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the sole Class of "residual interests" in REMIC I. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole Class of the "residual interests" in REMIC II. The An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class M-3 A-1, Class X-0X, Xxxxx X-0X, Xxxxx X-0X, Class A-AB, Class A-3, Class X-0X, Xxxxx X-0X, Xxxxx X-X, Class X-1, Class X-2, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O, Class P, Class Q and Class S Certificates shall be designated as Regular Interests the "regular interests" in REMIC III and the Class R-III Interest Certificates shall be designated as the Residual Interest sole Class of "residual interests" in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Paying Agent shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account, the Insurance Policies and any REO Properties as a REMIC under the Code, other than any portion of the foregoing amounts allocable to a Companion Loan. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the Regular Interests sole class of "residual interests" in REMIC II I. The Trustee and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Paying Agent shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I Regular Interests Interests, the REMIC II Regular Interests, the REMIC Regular Certificates and the interests represented Residual Certificates. An election will be made by the CertificatesPaying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interest is issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class R-II Certificates shall be designated as the sole class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class A-1, Class A-2, Class A-3, Class A-4, Class X-1, Class X-2, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M and Class N Certificates shall be designated as the "regular interests" in REMIC III and the Class R-III Certificates shall be designated as the sole class of "residual interests" in REMIC III.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account, the Insurance Policies and any REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Mortgage Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the Regular Interests sole Class of "residual interests" in REMIC II I. The Trustee and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Paying Agent shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests and the interests represented Residual Certificates. An election will be made by the CertificatesPaying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class R-II Certificates shall be designated as the sole Class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class A-1, Class A-2, Class A-3, Class A-4, Class X-1 (each Class X-1 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class X-2 (each Class X-2 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N and Class O Certificates shall be designated as the "regular interests" in REMIC III and the Class R-III Certificates shall be designated as the sole Class of "residual interests" in REMIC III.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account (exclusive of the Excess Interest Sub-Account), the Insurance Policies and any REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Mortgage Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the Regular Interests sole Class of "residual interests" in REMIC II I. The Trustee and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Paying Agent shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests and the interests represented Residual Certificates. An election will be made by the CertificatesPaying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class R-II Certificates shall be designated as the sole Class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class A-1, Class A-2, Class A-3, Class A-4, Class X-1 (each Class X-1 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class X-2 (each Class X-2 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O and Class P Certificates (but other than the Class P Grantor Trust Interest) shall be designated as the "regular interests" in REMIC III and the Class R-III Certificates shall be designated as the sole Class of "residual interests" in REMIC III.

REMIC Administration. (a) The Trustee REMIC elections as set forth in the Preliminary Statement shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form Forms 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. The regular interests and residual interest in each REMIC shall be as designated in the Preliminary Statement. For the purposes of the REMIC election in respect of REMIC Isuch designations, the REMIC I Regular Interests interest rate of any regular interest that is computed by taking into account the weighted average of the Net Mortgage Rates of the Mortgage Loans shall be designated as reduced by the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation amount of any "interests" expense paid by the Trust to the extent that (i) such expense was not taken into account in computing the Net Mortgage Rate of any Trust Mortgage Loan, (ii) such expense does not constitute an “unanticipated expense” of a REMIC (within the meaning of Treasury Regulation Section 860G 1.860G-1(b)(3)(ii) and (iii) the amount of such expense was not taken into account in computing the interest rate of a more junior Class of regular interests. The Closing Date is hereby designated as the “Startup Day” of each REMIC within the meaning of section 860G(a)(9) of the Code. The latest possible maturity date for purposes of Treasury Regulation 1.860G-1(a)(4) will be the Latest Possible Maturity Date. The Securities Administrator shall pay any and all tax related expenses (not including taxes) of each REMIC, including but not limited to any professional fees or expenses related to audits or any administrative or judicial proceedings with respect to such REMIC that involve the Internal Revenue Service or state tax authorities, but only to the extent that (i) such expenses are ordinary or routine expenses, including expenses of a routine audit but not expenses of litigation (except as described in (ii)); or (ii) such expenses or liabilities (including taxes and penalties) are attributable to the negligence or willful misconduct of the Securities Administrator in fulfilling its duties hereunder (including its duties as tax return preparer). The Securities Administrator shall be entitled to reimbursement of expenses to the extent provided in clause (i) above from the Securities Administration Account, provided, however, the Securities Administrator shall not be entitled to reimbursement for expenses incurred in connection with the preparation of tax returns and other reports as required by this Agreement. The Securities Administrator shall prepare, the Trustee shall sign and the Securities Administrator shall file, all of each REMIC’s federal and appropriate state tax and information returns as such REMIC’s direct representative. The expenses of preparing and filing such returns shall be borne by the Securities Administrator. The Securities Administrator or its designee shall perform on behalf of each REMIC all reporting and other tax compliance duties that are the responsibility of such REMIC under the Code, the REMIC Provisions, or other compliance guidance issued by the Internal Revenue Service or any state or local taxing authority. Among its other duties, if required by the Code, the REMIC Provisions, or other such guidance, the Securities Administrator shall provide (i) to the Treasury or other governmental authority such information as is necessary for the application of any tax relating to the transfer of a Residual Certificate to any disqualified person or organization pursuant to Treasury Regulation 1.860E-2(a)(5) and any person designated in Section 860E(e)(3) of the Code and (ii) to the Trustee such information as is necessary for the Trustee to provide to the Certificateholders such information or reports as are required by the Code or REMIC Provisions. The Trustee, the Securities Administrator, the Master Servicer and the Holders of Certificates shall take any action or cause any REMIC to take any action necessary to create or maintain the status of any REMIC as a REMIC under the REMIC Provisions and shall assist each other as necessary to create or maintain such status. None of the Trustee, the Securities Administrator, the Master Servicer and the Holder of any Residual Certificate shall knowingly take any action, cause any REMIC to take any action or fail to take (or fail to cause to be taken) any action that, under the REMIC Provisions, if taken or not taken, as the case may be, could result in an Adverse REMIC Event unless the Trustee, the Securities Administrator and the Master Servicer have received an Opinion of Counsel addressed to the Trustee (at the expense of the party seeking to take such action) to the effect that the contemplated action will not result in an Adverse REMIC Event. In addition, prior to taking any action with respect to any REMIC or the assets therein, or causing any REMIC to take any action, which is not expressly permitted under the terms of this Agreement, any Holder of a Residual Certificate will consult with the Trustee, the Securities Administrator, the Master Servicer or their respective designees, in writing, with respect to whether such action could cause an Adverse REMIC Event to occur with respect to any REMIC, and no such Person shall take any such action or cause any REMIC to take any such action as to which the Trustee, the Securities Administrator or the Master Servicer has advised it in writing that an Adverse REMIC Event could occur. Each Holder of a Residual Certificate shall pay when due any and all taxes imposed on the related REMIC by federal or state governmental authorities. To the extent that such taxes are not paid by a Residual Certificateholder, the Trustee shall pay any remaining REMIC taxes out of current or future amounts otherwise distributable to the Holder of the Residual Certificate in any such REMIC or, if no such amounts are available, out of other amounts held in the Collection Account, and shall reduce amounts otherwise payable to holders of regular interests in any such REMIC, as the case may be. The Securities Administrator shall, for federal income tax purposes, maintain books and records with respect to each REMIC on a calendar year and on an accrual basis. No additional contributions of assets after the Startup Day shall be made to any REMIC, except as expressly provided in this Agreement. Neither the Securities Administrator nor the Master Servicer shall enter into any arrangement by which any REMIC will receive a fee or other compensation for services. On or before October 15 of each calendar year beginning in 2006, the Securities Administrator shall deliver to the Trustee an Officer’s Certificate stating, without regard to any actions taken by any party other than the REMIC I Regular Interests Securities Administrator, the Securities Administrator’s compliance with provisions of this Section 11.01. Notwithstanding the priority and sources of payments set forth in Article VI hereof or otherwise, the interests represented by Securities Administrator shall account for all distributions on the CertificatesCertificates as set forth in this Section 11.01.

REMIC Administration. (a) The An election will be made by the Certificate Administrator on behalf of the Trustee shall elect to treat each Trust REMIC the segregated pool of assets consisting of the Mortgage Loans (other than any Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Collection Account, the Reserve Accounts and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and, to the extent of the Trust’s interest therein, any related REO Properties as a REMIC under the Code and(such REMIC being herein designated as “REMIC I”), if necessary, under applicable state lawother than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Loan. Each such election Such elections will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC I I, and the REMIC I Residual Interest (which shall be evidenced by the Class R-I Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC I. The Class A CertificatesAn election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC II”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the Class M-1 Certificates and the Class M-2 Certificates REMIC II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC II II, and the REMIC II Residual Interest (which shall be evidenced by the Class R-II Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC II. The Class M-3 Certificates shall An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC III”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Interests are issued. For purposes of such election, the Class A-1, Class A-2, Class A-SB, Class A-3, Class A-4, Class D, Class E, Class F, Class G and Class H Certificates, the EC Trust REMIC III Regular Interests in REMIC III and the Class R-X REMIC III Interest Regular Interests shall be designated as the “regular interests” in REMIC III, and the REMIC III Residual Interest (which shall be evidenced by the Class R Certificates) shall be designated as the sole class of “residual interests” in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Certificate Administrator shall not permit the creation of any "“interests" in any Trust REMIC ” (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Interests and the interests represented by the CertificatesREMIC III Interests.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will shall be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I, (i) the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A CertificatesI, (ii) the Class M-1 Certificates and the Class M-2 Certificates REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates , (iii) the REMIC III Regular Interests shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates , (iv) the REMIC IV Regular Interests shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The , (v) the Class M-5 A Certificates, the Mezzanine Certificates (exclusive of the right to receive payments from the Net WAC Carryover Reserve Account or the Swap Account or the obligation to make payments to the Swap Account), the Class SWAP-IO Interest, the Class A-2B1 Swap-IO Interest, the Class CE Interest and the Class P Interest shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The IV, (vi) the Class CE Certificates shall be designated as the Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The , (vii) the Class P Certificates shall be designated as the Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII, (viii) REMIC VIII Regular Interest SWAP-IO shall be designated as the Regular Interests in REMIC VIII and the Class R-VIII Interest shall be designated as the Residual Interest in REMIC VIII and (ix) REMIC IX Regular Interest Class A-2B1 Swap-IO shall be designated as the Regular Interests in REMIC IX and the Class R-IX Interest shall be designated as the Residual Interest in REMIC IX. The Trustee shall not permit the creation of any "“interests" ” in any Trust REMIC (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests Interests, the REMIC II Regular Interests, the REMIC III Regular Interests, the REMIC IV Regular Interests, the Class CE Interest, the Class P Interest, the Class SWAP-IO Interest, the Class A-2B1 Swap-IO Interest and the interests represented by the Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Each such Such election will be made by the Trust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC IA, the REMIC I A Regular Interests shall be designated as the Regular Interests in REMIC I A and the Class R-I A Residual Interest shall be designated as the Residual Interests in REMIC A. For the purposes of the REMIC election in respect of REMIC B, the REMIC B Regular Interests shall be designated as the Regular Interests in REMIC B and the Class R-B Residual Interest shall be designated as the Residual Interests in REMIC B. For the purposes of the REMIC election in respect of REMIC C, the Certificates or Components thereof (other than the Class R Certificates), shall be designated as the Regular Interests in REMIC C and the Class R-C Residual Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, C. Neither the Class M-1 Certificates and Trustee nor the Class M-2 Certificates Trust Administrator shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "“interests" ” in any Trust REMIC A, REMIC B or REMIC C (within the meaning of Section 860G of the Code) other than the REMIC I A Regular Interests, REMIC B Regular Interests and the interests represented Certificates. The Trustee shall elect to treat each REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Such election will be made by the CertificatesTrust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued.

REMIC Administration. (a) The Trustee Trust Administrator shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee Trust Administrator on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I, the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates, the Class M-2 Certificates, the Class M-3 Certificates (exclusive of any right to receive payments from the Net WAC Rate Carryover Account), the Class M-4 Interest, the Class M-5 Interest, the Class M-6 Interest, the Class M-7 Interest, the Class CE Interest and the Class M-2 Certificates P Interest shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 M-4 Certificates (exclusive of any right to receive payments from the Net WAC Rate Carryover Account) shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 M-5 Certificates (exclusive of any right to receive payments from the Net WAC Rate Carryover Account) shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 M-6 Certificates (exclusive of any right to receive payments from the Net WAC Rate Carryover Account) shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE M-7 Certificates (exclusive of any right to receive payments from the Net WAC Rate Carryover Account) shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P CE Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Class P Certificates shall be designated as Regular Interests in REMIC VIII and the Class R-VIII Interest shall be designated as the Residual Interest in REMIC VIII. Neither the Trustee nor the Trust Administrator shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests and the interests represented by the CertificatesResidual Interests named above.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Each such Such election will be made by the Trust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I-A, the REMIC I I-A Regular Interests shall be designated as the Regular Interests in REMIC I I-A and the Class R-I IA Residual Interest shall be designated as the Residual Interest Interests in REMIC I. The Class A CertificatesI-A. For the purposes of the REMIC election in respect of REMIC I-B, the Class M-1 Certificates and the Class M-2 Certificates REMIC I-B Regular Interests shall be designated as the Regular Interests in REMIC II I-B and the Class R-II IB Residual Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and I-B. For the purposes of the REMIC election in respect of REMIC I-B, the Group 1 Certificates (other than the Class R1-III Interest R Certificates) shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and I-B. Neither the Class R-IV Interest Trustee nor the Trust Administrator shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "“interests" ” in any Trust REMIC I-A or REMIC I-B (within the meaning of Section 860G of the Code) other than the REMIC I I-A Regular Interests, REMIC I-B Regular Interests and the interests represented Group 1 Certificates. For the purposes of the REMIC election in respect of REMIC II-A, the REMIC II-A Regular Interests shall be designated as the Regular Interests in REMIC II-A and the Class R-IIA Residual Interest shall be designated as the Residual Interests in REMIC II-A. For the purposes of the REMIC election in respect of REMIC II-B, the REMIC II-B Regular Interests shall be designated as the Regular Interests in REMIC II-B and the Class R-IIB Residual Interest shall be designated as the Residual Interests in REMIC II-B. For the purposes of the REMIC election in respect of REMIC II-B, the Group 2 Certificates (other than the Class 2-R Certificates) shall be designated as the Regular Interests in REMIC II-B and the Class R-IIC Residual Interest shall be designated as the Residual Interest in REMIC II-B. Neither the Trustee nor the Trust Administrator shall permit the creation of any “interests” in REMIC II-A, REMIC II-B or REMIC II-B (within the meaning of Section 860G of the Code) other than the REMIC II-A Regular Interests, REMIC II-B Regular Interests and the Group 2 Certificates. The Trustee shall elect to treat each REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Such election will be made by the CertificatesTrust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest, Exit Fees, Extension Fees or Extension Term Prepayment Premiums payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Account, the Interest Reserve Account, the Reserve Account and the Distribution Account (exclusive of the Class P Sub-account), the Insurance Policies and any related amounts in the REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Mortgage Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the sole Class of "residual interests" in REMIC I. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole Class of the "residual interests" in REMIC II. The An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class M-3 A-1, Class A-1A, Class A-2, Class A-3, Class A-M, Class A-J, Class X, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O and Class P Certificates (but other than the Class P Grantor Trust Interest) shall be designated as Regular Interests the "regular interests" in REMIC III and the Class R-III Interest Certificates shall be designated as the Residual Interest sole Class of "residual interests" in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Paying Agent shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Trustee on behalf of the Trust to treat the segregated pool of assets consisting of the Mortgage Loans (other than the right to Excess Interest in respect of the Anticipated Repayment Date Loans), such amounts as shall from time to time be held in the Collection Account and the Distribution Account in respect thereof, the Insurance Policies and any REO Properties and any other assets constituting REMIC I (as set forth on the definition of REMIC I) as 151 a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect such election, each of REMIC I, the REMIC I Regular Interests shall be designated as the Regular Interests a separate class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the sole class of "residual interests" in REMIC I. An election will be made by the Trustee on behalf of REMIC II to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole class of "residual interests" in REMIC II. The An election will be made by the Trustee on behalf of REMIC III to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class M-3 A-1, Class A-2, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, and Class N Certificates, the Class O Regular Interest represented by the Class O Certificates, and each Component Interest of the Class X Certificates shall be designated as Regular Interests the "regular interests" in REMIC III and the Class R-III Interest Certificates shall be designated as the Residual Interest sole class of "residual interests" in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Treasury regulation Section 860G 1.860D-1(b)(1)) in any of the Code) REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests and the interests represented evidenced by the Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Trustee Paying Agent to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account, the Insurance Policies and any REO Properties as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as a separate class of "regular interests" in the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the Regular Interests sole class of "residual interests" in the REMIC II and I. Neither the Class R-II Interest Trustee nor the Paying Agent shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I, REMIC II and REMIC III Regular Interests and the Residual Certificates. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interest is issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the interests represented Class R-II Certificates shall be designated as the sole class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class A-1, Xxxxx X-0, Xxass X, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, and Class N Certificates, together with the REMIC III Class O Regular Interest and the REMIC III Excess Interest, shall be designated as the "regular interests" in REMIC III and the Class R-III Certificates shall be designated as the sole class of "residual interests" in REMIC III.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Account, and the Interest Reserve Account, the Reserve Account and the Distribution Account (exclusive of the Class A-4FL Floating Rate Account, the Class A-MFL Floating Rate Account and the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Mortgage Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the sole Class of "residual interests" in REMIC I. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class R-II Certificates shall be designated as the sole Class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates, the Class A-4FL Regular Interest and the Class A-MFL Regular Interest are issued. For purposes of such election, the Class A-1, Class A-1A, Class A-2, Class A-3-1, Class A-3-2, Class A-AB, Class A-4, Class A-M, Class A-J, Class X, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O, Class P, Class Q and Class S Certificates, the Class A-4FL Regular Interest and the Class A-MFL Regular Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests "regular interests" in REMIC III and the Class R-III Interest Certificates shall be designated as the Residual Interest sole Class of "residual interests" in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Paying Agent shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests Interests, the REMIC II Regular Interests, the REMIC III Regular Certificates, the Class A-4FL Regular Interest, the Class A-MFL Regular Interest and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account, the Insurance Policies and any REO Properties as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as a separate class of "regular interests" in the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the Regular Interests sole class of "residual interests" in the REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. I. The Trustee shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I, REMIC II and REMIC III Regular Interests and the Residual Certificates. An election will be made by the Trustee to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interest is issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the interests represented Class R-II Certificates shall be designated as the sole class of the "residual interests" in REMIC II. An election will be made by the CertificatesTrustee to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class X-0, Xxxxx X-0, Class X, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O and Class P Certificates shall be designated as the "regular interests" in REMIC III and the Class R-III Certificates shall be designated as the sole class of "residual interests" in REMIC III.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Xxxxxxx Xxxx Loan, such amounts related to the Xxxxxxx Xxxx Loan as shall from time to time be held in the Certificate Account, the Interest Reserve Account and the Distribution Account, the related Insurance Policies and any related REO Properties as a REMIC ("Xxxxxxx Xxxx Loan REMIC ") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates Xxxxxxx Xxxx Loan REMIC Interests are issued. For purposes of such election, the Xxxxxxx Xxxx Loan REMIC Regular Interests shall each be designated as a Class of "regular interests" in the Xxxxxxx Xxxx Loan REMIC and the Xxxxxxx Xxxx Loan REMIC Residual Interest shall be designated as the sole Class of "residual interests" in the Xxxxxxx Xxxx Loan REMIC. An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Majority Mortgage Loans, the Xxxxxxx Xxxx Loan REMIC Regular Interest, such amounts related to the Majority Mortgage Loans as shall from time to time be held in the Certificate Account and the Interest Reserve Account, such amounts related to the Majority Mortgage Loans and the Xxxxxxx Xxxx Loan REMIC Regular Interest as shall from time to time be held in the Distribution Account (exclusive of the Excess Interest Sub-account and the Xxxxxxx Xxxx Sub-account), the related Insurance Policies and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or the WestShore Plaza Companion Loan. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC I Interests are issued. For purposes of such election, the REMIC I Regular Interests shall each be designated as a separate Class of "regular interests" in REMIC I and the REMIC I Residual Interest shall be designated as the sole Class of "residual interests" in REMIC I. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I II Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the Regular Interests "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole Class of the "residual interests" in REMIC II. The An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class M-3 A-1, Class A-2, Class A-3, Class A-4, Class X-1 (each Class X-1 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class X-2 (each Class X-2 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N and Class O Certificates (but other than the Class A-1, Class X-1, Class X-2 and Class O Grantor Trust Interest) shall be designated as Regular Interests the "regular interests" in REMIC III and the Class R-III Interest Certificates shall be designated as the Residual Interest sole Class of "residual interests" in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Paying Agent shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMICs other than the Xxxxxxx Xxxx Loan REMIC Regular Interest, REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Each such Such election will be made by the Trust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I-A, the REMIC I I-A Regular Interests shall be designated as the Regular Interests in REMIC I I-A and the Class R-I IA Residual Interest shall be designated as the Residual Interests in REMIC I-A. For the purposes of the REMIC election in respect of REMIC I-B, the REMIC I-B Regular Interests shall be designated as the Regular Interests in REMIC I-B and the Class R-IIB Residual Interest shall be designated as the Residual Interests in REMIC I-B. For the purposes of the REMIC election in respect of REMIC I-C, the Group 1 Certificates (other than the Class 1-R Certificates) shall be designated as the Regular Interests in REMIC I-C and the Class R-IC Residual Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, I-C. Neither the Class M-1 Certificates and Trustee nor the Class M-2 Certificates Trust Administrator shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "“interests" ” in any Trust REMIC I-A, REMIC I-B or REMIC I-C (within the meaning of Section 860G of the Code) other than the REMIC I I-A Regular Interests, REMIC I-B Regular Interests and the interests represented Group 1 Certificates. For the purposes of the REMIC election in respect of REMIC II, the Group 2 Certificates (other than the Class 2-R Certificates) shall be designated as the Regular Interests in REMIC II. Neither the Trustee nor the Trust Administrator shall permit the creation of any “interests” other than the Group 2 Certificates. The Trustee shall elect to treat each REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Such election will be made by the CertificatesTrust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued.

REMIC Administration. (a) The Trustee REMIC elections as set forth in the Preliminary Statement shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. The regular interests and residual interest in each REMIC shall be as designated in the Preliminary Statement. For the purposes of the REMIC election elections in respect of the Trust Fund, (i) the REMIC I1 Regular Interests will represent the “regular interests” in REMIC 1, the Class R-1 Interest will constitute the sole class of “residual interests” in REMIC I 1, (ii) the REMIC 2 Regular Interests shall be designated as will represent the Regular Interests “regular interests” in REMIC I 2, the Class R-2 Interest will constitute the sole class of “residual interests” in REMIC 2, (iii) the Class A Certificates, the Class M Certificates and the Class R-I B Certificates (exclusive of any right to receive distributions from the Net WAC Rate Carryover Reserve Account in respect of the Net WAC Rate Carryover Amount or the Swap Account or any obligation to make payments to the Swap Account), the Class C Interest, the Class IO Interest and the Class P Interest shall be designated as the Residual Interest “regular interests” in REMIC I. The Class A Certificates, the Class M-1 Certificates 3 and the Class M-2 Certificates shall be designated as R-3 Interest will constitute the Regular Interests sole class of “residual interests” in REMIC II 3, (iv) the Class C Certificates (exclusive of any obligation to make payments to the Net WAC Rate Carryover Reserve Account in respect of the Net WAC Rate Carryover Amount) will represent ownership of “regular interests” in REMIC 4 and the Class R-4 Interest will constitute the sole class of “residual interests” in REMIC 4, (v) the Class P Certificates will represent ownership of “regular interests” in REMIC 5 and the Class R-5 Interest will constitute the sole class of “residual interests” in REMIC 5, (vi) the REMIC 6 Regular Interest SWAP IO will represent ownership of “regular interests” in REMIC 6 and the Class R-6 Interest will constitute the sole class of “residual interests” in REMIC 6, (vii) the Class R Certificates will evidence ownership of the Class R-1 Interest, Class R-2 Interest and Class R-3 Interest and (viii) the Class R-II X Certificates will evidence ownership of the Class R-4 Interest, the Class R-5 Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC IIIR-6 Interest. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Securities Administrator and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "“interests" in any Trust REMIC ” (within the meaning of Section 860G of the Code) in any REMIC created hereunder other than (a) the REMIC I 1 Regular Interests, the REMIC 2 Regular Interests, the REMIC 3 Regular Interests, the REMIC 4 Regular Interests, the REMIC 5 Regular Interests and or the interests REMIC 6 Regular Interests, the ownership of which is represented by the Class A Certificates., the Class M Certificates, the Class B Certificates, the REMIC 6 Regular Interest SWAP IO, the Class C Certificates and the Class P Certificates and (b) the Class R-1 Interest, the Class R-2 Interest, the Class R-3 Interest, the Class R-4 Interest, the Class R-5 Interest and the Class R-6 Interest. The Securities Administrator will apply for an Employee Identification Number from the IRS via form SS-4 or any other acceptable method for each Trust REMIC

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Trustee Paying Agent to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account, the Insurance Policies and any REO Properties as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as a separate class of "regular interests" in the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the Regular Interests sole class of "residual interests" in the REMIC II and I. Neither the Class R-II Interest Trustee nor the Paying Agent shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I, REMIC II and REMIC III Regular Interests and the Residual Certificates. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interest is issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the interests represented Class R-II Certificates shall be designated as the sole class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class X-0, Xxxxx X-0, Class X, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class I, Class J, Class K and Class L Certificates, together with the REMIC III Class M Regular Interest and the REMIC III Excess Interest, shall be designated as the "regular interests" in REMIC III and the Class R-III Certificates shall be designated as the sole class of "residual interests" in REMIC III.

REMIC Administration. (a) The An election will be made by the Certificate Administrator on behalf of the Trustee shall elect to treat each Trust REMIC the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Collection Account, the Reserve Accounts and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and, to the extent of the Trust’s interest therein, any related REO Properties as a REMIC under the Code and(such REMIC being herein designated as “REMIC I”), if necessary, under applicable state lawother than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Loan. Each such election Such elections will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC I I, and the REMIC I Residual Interest (which shall be evidenced by the Class R-I Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC I. The Class A CertificatesAn election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code (such REMIC being herein designated as “REMIC II”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the Class M-1 Certificates and the Class M-2 Certificates REMIC II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC II II, and the REMIC II Residual Interest (which shall be evidenced by the Class R-II Interest R Certificates) shall be designated as the Residual Interest sole class of “residual interests” in REMIC II. The Class M-3 Certificates shall An election will be made by the Certificate Administrator to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code (such REMIC being herein designated as Regular Interests “REMIC III”). Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Interests are issued. For purposes of such election, the Class A-0, Xxxxx X-0, Class A-AB, Class A-0, Xxxxx X-0, Class D, Class E, Class F, Class G and Class H Certificates, the EC Trust REMIC III Regular Interests, the Swap REMIC III Regular Interests, the Class J REMIC III Regular Interest and the Class R-X REMIC III Interest Regular Interests shall be designated as the “regular interests” in REMIC III, and the REMIC III Residual Interest (which shall be evidenced by the Class R Certificates) shall be designated as the sole class of “residual interests” in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Certificate Administrator shall not permit the creation of any "“interests" in any Trust REMIC ” (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Interests and the interests represented by the CertificatesREMIC III Interests.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account, the Insurance Policies and any REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or the RSA Companion Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the Regular Interests sole Class of "residual interests" in REMIC II I. The Trustee and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Paying Agent shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests and the interests represented Residual Certificates. An election will be made by the CertificatesPaying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class R-II Certificates shall be designated as the sole Class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class A-1, Class A-2, Class A-3, Class A-4, Class X-1 (each Class X-1 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class X-2 (each Class X-2 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M and Class N Certificates shall be designated as the "regular interests" in REMIC III and the Class R-III Certificates shall be designated as the sole Class of "residual interests" in REMIC III.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Trustee on behalf of the Trust to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Collection Account and the Distribution Account, the Insurance Policies and any REO Properties and any other assets constituting REMIC I (as set forth on the definition of REMIC I) as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I 156 Regular Interests shall each be designated as the Regular Interests a separate class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the sole class of "residual interests" in REMIC I. An election will be made by the Trustee on behalf of REMIC II to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole class of "residual interests" in REMIC II. The An election will be made by the Trustee on behalf of REMIC III to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class M-3 A1, Class A2, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K and Class L Certificates and each Component Interest of the Class X Certificates shall be designated as Regular Interests the "regular interests" in REMIC III and the Class R-III Interest Certificates shall be designated as the Residual Interest sole class of "residual interests" in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Treasury regulation Section 860G 1.860D-1(b)(1)) in any of the Code) REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests and the interests represented evidenced by the Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each that the Trust REMIC Fund be treated as a REMIC under the Code and, if necessary, under two separate REMICs for federal and any applicable state lawand local income tax purposes. Each such election The Class R Certificates will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day represent beneficial ownership of the calendar year in which the Certificates are issuedClass R1 Interest and Class R2 Interest. For the purposes The Owner of the REMIC election in respect Class R Certificate representing the largest Percentage Interest of REMIC I, the REMIC I Regular Interests shall be Residual Certificates is hereby designated as the Regular Interests "tax matters person" as defined in the REMIC I Provisions (the "Tax Matters Person") with respect to each of REMIC 1 and REMIC 2. The Trustee shall treat each Class of Offered Certificates as a regular interest with a principal balance equal to the applicable Class R-I Interest shall be designated as Certificate Principal Balance for such Distribution Date plus Basis Risk Shortfalls for such Distribution Date and, in the Residual Interest in REMIC I. The case of the Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the Regular Interests in REMIC II and the Class R-II right to receive Supplemental Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VIIPayments. The Trustee shall not permit treat the creation Certificateholder's right to receive payments of Basis Risk Shortfall and in the case of the Class A Certificates, the right to receive Supplemental Interest Payments as an interest rate cap agreement (the "Cap Agreement") that the Trustee holds separate and apart from the portion of the Offered Certificates treated as a REMIC regular interest and shall treat each Offered Certificateholder as owning the portion of the Offered Certificate treated as a REMIC regular interest issued by REMIC 2 and the Cap Agreement through a trust treated as a grantor trust under subpart E of part I of subchapter J of Chapter 1 of subtitle A of the Code. Notwithstanding any "interests" in any Trust REMIC (other provision of this Agreement, the Basis Risk Reserve Fund shall be treated as an outside reserve fund within the meaning of Treasury Regulation Section 860G 1.860G-2(h) and not an asset of any REMIC created pursuant to this Agreement, the owners of the CodeBasis Risk Reserve Fund shall be the owner(s) other than of the Class X Certificates, and for all federal tax purposes, amounts transferred by REMIC I Regular Interests 2 to the Basis Risk Reserve Fund shall be treated as distributed by REMIC 2 to the owner(s) of the Class X Certificates and owners of the Class X Certificates, shall include as income their pro rata share of the income of such fund including income from the regular interests ownership of which is represented by the Class X Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account, the Insurance Policies and any REO Properties as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the Corresponding REMIC I Regular Interests shall each be designated as a separate class of "regular interests" in the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the Regular Interests sole class of "residual interests" in the REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. I. The Trustee shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I, REMIC II and REMIC III Regular Interests and the Residual Certificates. An election will be made by the Trustee to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interest is issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the interests represented Class R-II Certificates shall be designated as the sole class of the "residual interests" in REMIC II. An election will be made by the CertificatesTrustee to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class A-1, Class A-2, Class X-1, Class X-2, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J and Class K Certificates shall be designated as the "regular interests" in REMIC III and the Class R-III Certificates shall be designated as the sole class of "residual interests" in REMIC III.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Accounts, the Interest Reserve Accounts, the Distribution Account and the Reserve Account, the Insurance Policies and any related amounts REO Account and any related REO Properties as a REMIC (“REMIC I”) under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC I Interests are issued. For purposes of such election, the REMIC I Regular Interests shall each be designated as a separate class of “regular interests” in REMIC I and the Class [R-I] Certificates shall be designated as the sole class of “residual interests” in REMIC I. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC (“REMIC II”) under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I II Regular Interests shall be designated as the Regular Interests “regular interests” in REMIC I II and the Class [R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 II] Certificates shall be designated as the sole class of the “residual interests” in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC (“REMIC III”) under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II III Certificates are issued. For purposes of such election, the Class [A-1], Class [A-1A], Class [A-2], Class [A-3-1], Class [A-3-2], Class [A-AB], Class [A-4A], Class [A-4B], Class [A-1A], Class [A-J], Class [B], Class [C], Class [D], Class [E], Class [F], Class [G], Class [H], Class [J], Class [K], Class [L], Class [M], Class [N], Class [O], Class [P], Class [X-1], Class [X-2] and Class [X-Y] Certificates and the Class RA-3-II Interest 1FL Regular Interest, shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests “regular interests” in REMIC III and the Class [R-III Interest III] Certificates shall be designated as the Residual Interest sole class of “residual interests” in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Paying Agent shall not permit the creation of any "“interests" in any Trust REMIC ” (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return (including Form 8811) or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued, copies of which forms and returns shall promptly be furnished by the Trustee to the NIMS Insurer. For the purposes of the REMIC election in respect of REMIC I1, the REMIC I 1 Regular Interests shall be designated as the Regular Interests in REMIC I 1 and the Class R-I R‑1 Interest shall be designated as the Residual Interest in REMIC I. 1. For the purposes of the REMIC election in respect of REMIC 2, the REMIC 2 Regular Interests shall be designated as the Regular Interests in REMIC 2 and the Class R-2 Interest shall be designated as the Residual Interest in REMIC 2. The REMIC 3 Regular Interests shall be designated as the Regular Interests in REMIC 3 and the Class A CertificatesR-3 Interest shall be designated as the Residual Interest in REMIC 3. For the purposes of the REMIC election in respect of REMIC CX, the Class M-1 Certificates and the Class M-2 C Certificates shall be designated as the Regular Interests in REMIC II CX and the Class R-II R‑CX Interest shall be designated as the Residual Interest in REMIC IICX. The For the purposes of the REMIC election in respect of REMIC PX, the Class M-3 P Certificates shall be designated as the Regular Interests in REMIC III PX and the Class R-III R‑PX Interest shall be designated as the Residual Interest in REMIC IIIPX. The For the purposes of the REMIC election in respect of REMIC SwapX, the Class M-4 Certificates Swap IO Upper-Tier Interest shall be designated as the Regular Interests in REMIC IV SwapX and the Class R-IV SwapX Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. SwapX. The Trustee shall not permit the creation of any "“interests" ” in any Trust REMIC 1, REMIC 2, REMIC 3, REMIC 4, REMIC CX, REMIC SwapX or REMIC PX (within the meaning of Section 860G of the Code) other than the REMIC I 1 Regular Interests, the REMIC 2 Regular Interests, the REMIC 3 Regular Interests and the interests represented by the Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account, the Insurance Policies and any REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note and Companion Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the Regular Interests sole Class of "residual interests" in REMIC II I. The Trustee and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Paying Agent shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests and the interests represented Residual Certificates. An election will be made by the CertificatesPaying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class R-II Certificates shall be designated as the sole Class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class A-1, Class A-2, Class A-3, Class X-1 (each Class X-1 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class X-2 (each Class X-2 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N and Class O Certificates shall be designated as the "regular interests" in REMIC III and the Class R-III Certificates shall be designated as the sole Class of "residual interests" in REMIC III.

REMIC Administration. The parties intend that the -------------------- Trust Estate formed hereunder shall consist of, and that the affairs of the Trust Estate shall be conducted so as to qualify it as a REMIC. In furtherance of such intention, the Trustee covenants and agrees that it shall act as agent (and the Trustee is hereby appointed to act as agent) on behalf of the Trust Estate and that in such capacity it shall: (a) The prepare and file, or cause to be prepared and filed, such federal, state and local income tax and information returns or reports using the calendar year as the taxable year for the REMIC and the accrual method of accounting when and as required by the REMIC Provisions and other applicable federal, state and local income tax laws, which returns or reports shall be signed by the Trustee shall elect or such other person as may be required thereby; (b) make an election, on behalf of the Trust Estate, to treat each be treated as a REMIC and make the appropriate designations in accordance with Section 2.05 hereof on the federal income tax return of the REMIC for its first taxable year, in accordance with the REMIC Provisions; (c) prepare and forward, or cause to be prepared and forwarded, to the Certificateholders all information reports, or furnish or cause to be furnished by telephone, mail, publication or other appropriate method such information, as and when required to be provided to them in accordance with the Code; (d) maintain such records relating to the Trust REMIC Estate, including but not limited to the income, expenses, individual Mortgage Loans (including REO Mortgage Loans), other assets and liabilities of the Trust Estate, and the adjusted basis of the Trust Estate property determined at such intervals as may be required by the Code, as may be necessary to prepare the foregoing returns, schedules, statements or information; (e) use its best efforts to conduct the affairs of the Trust Estate at all times that any Class of Certificates is outstanding so as to maintain the status thereof as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by REMIC Provisions; (f) not knowingly or intentionally take any action or omit to take any action that would cause the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes termination of the REMIC election in respect status of REMIC I, the Trust Estate or that would subject the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall to tax; (g) exercise reasonable care not permit to allow the creation of any "interests" in any Trust the REMIC (within the meaning of Code Section 860G of the Code860D(a)(2) other than the REMIC I Regular Interests and the interests represented by the Class A-1, Class A-2, Class A-3, Class A-R, Class A-PO, Class B-1, Class B-2, Class B-3, Class B- 4, Class B-5 and Class B-6 Certificates; (h) exercise reasonable care not to allow the occurrence of any "prohibited transactions" within the meaning of Code Section 860F(a), unless the Trustee shall have received an Opinion of Counsel that such occurrence would not (i) result in a taxable gain, (ii) otherwise subject the REMIC to tax, or (iii) cause the Trust Estate to fail to qualify as a REMIC; (i) exercise reasonable care not to allow the Trust Estate to receive income from the performance of services or from assets not permitted under the REMIC Provisions to be held by a REMIC; (j) pay (on behalf of the REMIC) the amount of any federal income tax and applicable state and local taxes, including, without limitation, prohibited transaction taxes, taxes on net income from foreclosure property, and taxes on certain contributions to a REMIC after the Startup Day, imposed on the REMIC when and as the same shall be due and payable (but such obligation shall not prevent the Trustee or any other appropriate Person from contesting any such tax in appropriate proceedings and shall not prevent the Trustee from withholding or depositing payment of such tax, if permitted by law, pending the outcome of such proceedings); (k) if required or permitted by the Code and applicable law, act as "tax matters person" for the REMIC within the meaning of Treasury regulations Section 1.860F- 4(d), and the Trustee is hereby designated as agent of the Class A-R Certificateholder for such purpose (or if the Trustee is not so permitted, the Holder of the Class A-R Certificate shall be the tax matters person in accordance with the REMIC Provisions); and (l) within 30 days of the Startup Day, file or cause to be filed with the Internal Revenue Service, on Form 8811 or as may otherwise be required by the Code, the name, title, address, and telephone number of the person that Certificateholders may contact for tax information relating to their Certificates (and the Trustee shall act as the representative of the REMIC for this purpose), together with such additional information as may be required by such Form, and shall update such information at the time and in the manner required by the Code. The Trustee shall be entitled to be reimbursed pursuant to Section 3.05 for any taxes paid by it pursuant to clause (j) of the preceding sentence, except to the extent that such taxes are imposed as the result of the bad faith, willful misfeasance or gross negligence of the Trustee in the performance of its obligations hereunder. The Servicer shall at all times act in such a manner in the performance of its duties hereunder as shall be necessary to prevent the Trust Estate from failing to qualify as a REMIC and to prevent the imposition of a tax on the REMIC.

REMIC Administration. (a) The Trustee Trust Administrator shall elect to treat each Trust REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. The Trust Administrator shall elect to treat the segregated pool of assets consisting of the portion of the Trust Fund related to the Pool I Mortgage Loans (exclusive of the Interest Coverage Account, Pool I Swap Agreement, the Pool I Swap Account and the Pool I Net WAC Rate Carryover Reserve Account and any Servicer Prepayment Payment Amounts) as a REMIC for federal income tax purposes, and such segregated pool of assets will be designated as “REMIC I.” For the purposes of the REMIC election in respect of REMIC I, the REMIC I Regular Interests shall be designated as the Regular Interests regular interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest residual interest in REMIC I. The Class A CertificatesTrust Administrator shall elect to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC for federal income tax purposes and such segregated pool of assets shall be designated as “REMIC II.” For the purposes of the REMIC election in respect of REMIC II, the Class M-1 Certificates and the Class M-2 Certificates REMIC II Regular Interests shall be designated as the Regular Interests regular interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest residual interest in REMIC II. The Class M-3 Certificates Trust Administrator shall elect to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC for federal income tax purposes and such segregated pool of assets shall be designated as “REMIC III.” For the purposes of the REMIC election in respect of REMIC III, the REMIC III Regular Interests shall be designated as the regular interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest residual interest in REMIC III. The Class M-4 Certificates Trust Administrator shall elect to treat the segregated pool of assets consisting of the portion of the Trust Fund related to the Pool II Mortgage Loans (exclusive of the Interest Coverage Account, Pool II Swap Agreement, the Pool II Swap Account and the Pool II Net WAC Rate Carryover Reserve Account and any Servicer Prepayment Payment Amounts) as a REMIC for federal income tax purposes, and such segregated pool of assets will be designated as “REMIC IV.” For the purposes of the REMIC election in respect of REMIC IV, the REMIC IV Regular Interests shall be designated as Regular Interests the regular interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest residual interests in REMIC IV. The Class M-5 Certificates Trust Administrator shall elect to treat the segregated pool of assets consisting of the REMIC IV Regular Interests as a REMIC for federal income tax purposes, and such segregated pool of assets shall be designated as “REMIC V.” For the purposes of the REMIC election in respect of REMIC V, the REMIC V Regular Interests shall be designated as the regular interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest residual interest in REMIC V. The Class CE Certificates Trust Administrator shall elect to treat the segregated pool of assets consisting of the REMIC V Regular Interests as a REMIC for federal income tax purposes, and such segregated pool of assets shall be designated as “REMIC VI.” For the purposes of the REMIC election in respect of REMIC VI, the REMIC VI Regular Interests shall be designated as the regular interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest residual interest in REMIC VI. The Class P Certificates Trust Administrator shall make an election to treat the segregated pool of assets consisting of the REMIC III Regular Interests and the REMIC VI Regular Interests as a REMIC for federal income tax purposes, and such segregated pool of assets will be designated as “REMIC VII.” For the purposes of the REMIC election in respect of REMIC VII, the REMIC VII Regular Interests shall be designated as Regular Interests the regular interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest residual Fremont 2006-B Pooling & Servicing Agreement 260 interest in REMIC VII. The Trust Administrator shall make an election to treat the segregated pool of assets consisting of the Class C Interest as a REMIC for federal income tax purposes, and such segregated pool of assets will be designated as “REMIC VIII.” For the purposes of the REMIC election in respect of REMIC VIII, the REMIC VIII Regular Interest shall be designated as the regular interest in REMIC VIII, and the Class RX-VIII Interest shall be designated as the residual interest in REMIC VIII. The Trust Administrator shall make an election to treat the segregated pool of assets consisting of the Class P Interest as a REMIC for federal income tax purposes, and such segregated pool of assets will be designated as “REMIC IX.” For the purposes of the REMIC election in respect of REMIC IX, the REMIC IX Regular Interest shall be designated as the regular interest in REMIC IX, and the Class RX-IX Interest shall be designated as the residual interest in REMIC IX. The Trust Administrator shall make an election to treat the segregated pool of assets consisting of the Class SWAP-I-IO Interest as a REMIC for federal income tax purposes, and such segregated pool of assets shall be designated as “REMIC X.” For the purposes of the REMIC election in respect of REMIC X, the REMIC X Regular Interest shall be designated as the regular interest in REMIC X, and the Class RX-X Interest shall be designated as the residual interest in REMIC X. The Trust Administrator shall make an election to treat the segregated pool of assets consisting of the Class SL-C Interest as a REMIC for federal income tax purposes, and such segregated pool of assets will be designated as “REMIC XI.” For the purposes of the REMIC election in respect of REMIC XI, the REMIC XI Regular Interest shall be designated as the regular interest in REMIC XI, and the Class RX-XI Interest shall be designated as the residual interest in REMIC XI. The Trust Administrator shall make an election to treat the segregated pool of assets consisting of the Class SWAP-II-IO Interest as a REMIC for federal income tax purposes, and such segregated pool of assets will be designated as “REMIC XII.” For the purposes of the REMIC election in respect of REMIC XII, the REMIC XII Regular Interest shall be designated as the regular interest in REMIC XII, and the Class RX-XII Interest shall be designated as the residual interest in REMIC XII. Neither the Trustee nor the Trust Administrator shall not permit the creation of any "“interests" ” in any Trust REMIC created hereunder (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests and the interests represented by the Certificatesthose designated above.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Each such Such election will be made by the Trust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I-A, the REMIC I I-A Regular Interests shall be designated as the Regular Interests in REMIC I I-A and the Class R-I IA Interest shall be designated as the Residual Interests in REMIC I-A. For the purposes of the REMIC election in respect of REMIC I-B, the REMIC I-B Regular Interests shall be designated as the Regular Interests in REMIC I-B and the Class R-IB Interest shall be designated as the Residual Interest in REMIC I. The Class A CertificatesI-B. For the purposes of the REMIC election in respect of REMIC I-C, the Class M-1 Group 1 Certificates and (other than the Class M-2 Certificates 1-R Certificates) shall be designated as the Regular Interests in REMIC II I-C and the Class R-II IC Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates I-C. Neither the Trustee nor the Trust Administrator shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "“interests" ” in any Trust REMIC I-A, REMIC I-B or REMIC I-C (within the meaning of Section 860G of the Code) other than the REMIC I I-A Regular Interests, the REMIC I-B Regular Interests and the interests represented Group 1 Certificates. For the purposes of the REMIC election in respect of REMIC II-A, the REMIC II-A Regular Interests shall be designated as the Regular Interests in REMIC II-A and the Class R-IIA Interest shall be designated as the Residual Interests in REMIC II-A. For the purposes of the REMIC election in respect of REMIC II-B, the Group 2 Certificates (other than the Class 2-R Certificates) shall be designated as the Regular Interests in REMIC II-B and the Class R-IID Interest shall be designated as the Residual Interest in REMIC II-B. Neither the Trustee nor the Trust Administrator shall permit the creation of any “interests” in REMIC II-A or REMIC II-B (within the meaning of Section 860G of the Code) other than the REMIC II-A Regular Interests and the Group 2 Certificates. The Trustee shall elect to treat each REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Such election will be made by the CertificatesTrust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Account, the Interest Reserve Account, the Reserve Account and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Mortgage Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the sole Class of "residual interests" in REMIC I. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in -258- which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole Class of the "residual interests" in REMIC II. The An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class M-3 A-1, Class A-2, Class A-3, Class A-AB, Class A-4, Class A-1A, Class A-M, Class A-J, Xxxxx X, Xxxss B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O and Class P Certificates (but other than the Class P Grantor Trust Interest) shall be designated as Regular Interests the "regular interests" in REMIC III and the Class R-III Interest Certificates shall be designated as the Residual Interest sole Class of "residual interests" in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Paying Agent shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Kimball Lane Loan, such amounts related to the Kimball Lane Loan as xxxxx xxxx time to time be held in the Certifixxxx Xxxxxxx, the Interest Reserve Account and the Distribution Account, the related Insurance Policies and any related REO Properties as a REMIC ("Kimball Lane Loan REMIC ") under the Code. Such election will be maxx xx Xxxx 0066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Kimball Lane Loan REMIC Interests are issued. For purposes of such xxxxxxxx, xxe Kimball Lane Loan REMIC Regular Interests shall each be designated xx x Xxxxx xf "regular interests" in the Kimball Lane Loan REMIC and the Kimball Lane Loan REMIC Residual Inxxxxxx xxxxx be designated as thx xxxx Xxxxx of "residual interests" in the Kimball Lane Loan REMIC. An election will be madx xx xxx Xxxing Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Majority Mortgage Loans, the Kimball Lane Loan REMIC Regular Interest, such amounts related to txx Xxxxxxxx Mortgage Loans as shall from time to time be held in the Certificate Account and the Interest Reserve Account, such amounts related to the Majority Mortgage Loans and the Kimball Lane Loan REMIC Regular Interest as shall from time to time xx xxxx xx the Distribution Account (exclusive of the Excess Interest Sub- account and the Kimball Lane Sub-account), the related Insurance Policies and any rxxxxxx XXX Xroperties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or the WestShore Plaza Companion Loan. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For purposes of such election, the REMIC I Regular Interests shall each be designated as a separate Class of "regular interests" in REMIC I and the REMIC I Residual Interest shall be designated as the sole Class of "residual interests" in REMIC I. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I II Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the Regular Interests "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole Class of the "residual interests" in REMIC II. The An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class M-3 A-1, Class A-2, Class A-3, Class A-4, Class X-1 (each Class X-1 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class X-2 (each Class X-2 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N and Class O Certificates (but other than the Class A-1, Class X-1, Class X-2 and Class O Grantor Trust Interest) shall be designated as Regular Interests the "regular interests" in REMIC III and the Class R-III Interest Certificates shall be designated as the Residual Interest sole Class of "residual interests" in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Paying Agent shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMICs other than the Kimball Lane Loan REMIC Regular Interest, REMIC I Regular Interests, xxx XXXXX II Regular Interests, the REMIC III Regular Interests and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee REMIC elections as set forth in the Preliminary Statement shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. The regular interests and residual interest in each REMIC shall be as designated in the Preliminary Statement. For the purposes of the REMIC election elections in respect of the Trust Fund, (i) the REMIC I1 Regular Interests will represent the “regular interests” in REMIC 1, the Class R-1 Interest will constitute the sole class of “residual interests” in REMIC I 1, (ii) the REMIC 2 Regular Interests shall be designated as will represent the Regular Interests “regular interests” in REMIC I 2, the Class R-2 Interest will constitute the sole class of “residual interests” in REMIC 2, (iii) the Class A Certificates and the Class R-I M Certificates (exclusive of any right to receive distributions from or obligations to make payments to the Net WAC Rate Carryover Reserve Account in respect of the Net WAC Rate Carryover Amount or the Swap Account), the Class C Interest, the Class IO Interest and the Class P Interest shall be designated as the Residual Interest “regular interests” in REMIC I. The Class A Certificates, the Class M-1 Certificates 3 and the Class M-2 Certificates shall be designated as R-3 Interest will constitute the Regular Interests sole class of “residual interests” in REMIC II 3, (iv) the Class C Certificates (exclusive of any right to receive distributions from or obligation to make payments to the Net WAC Rate Carryover Reserve Account in respect of the Net WAC Rate Carryover Amount or the Swap Account) will represent ownership of “regular interests” in REMIC 4 and the Class R-4 Interest will constitute the sole class of “residual interests” in REMIC 4, (v) the Class P Certificates will represent ownership of “regular interests” in REMIC 5 and the Class R-5 Interest will constitute the sole class of “residual interests” in REMIC 5, (vi) the REMIC 6 Regular Interest SWAP IO will represent ownership of “regular interests” in REMIC 6 and the Class R-6 Interest will constitute the sole class of “residual interests” in REMIC 6, (vii) the Class R Certificates will evidence ownership of the Class R-1 Interest, Class R-2 Interest and Class R-3 Interest and (viii) the Class R-II X Certificates will evidence ownership of the Class R-4 Interest, the Class R-5 Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC IIIR-6 Interest. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Securities Administrator and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "“interests" in any Trust REMIC ” (within the meaning of Section 860G of the Code) in any REMIC created hereunder other than (a) the REMIC I 1 Regular Interests, the REMIC 2 Regular Interests, the REMIC 3 Regular Interests, the REMIC 4 Regular Interests, the REMIC 5 Regular Interests and or the interests REMIC 6 Regular Interests, the ownership of which is represented by the Class A and Class M Certificates., the SWAP IO, the Class C Certificates and the Class P Certificates and (b) the Class R-1 Interest, the Class R-2 Interest, the Class R-3 Interest, the Class R-4 Interest, the Class R-5 Interest and the Class R-6 Interest. The Securities Administrator will apply for an Employee Identification Number from the IRS via form SS-4 or any other acceptable method for each Trust REMIC

REMIC Administration. (a) It is intended that the Trust Fund shall constitute and that the affairs of the Trust Fund shall be conducted so that each Trust REMIC shall qualify as a REMIC. The Trustee shall act as agent and the Trustee is hereby appointed to act as agent on behalf of the Trust Fund and in such capacity it shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will shall be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC Ieach Trust REMIC, (i) the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the sole class of Residual Interest in REMIC I. The Class A CertificatesI, (ii) the Class M-1 Certificates and the Class M-2 Certificates REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the sole class of Residual Interest in REMIC II. The Class M-3 Certificates , (iii) the REMIC III Regular Interests shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the sole class of Residual Interest in REMIC III. The , (iv) the Class M-4 Certificates C Interest shall be designated as the Regular Interests Interest in REMIC IV and the Class R-IV Interest shall be designated as the sole class of Residual Interest in REMIC IV. The , (v) the Class M-5 Certificates P Interest shall be designated as the Regular Interests Interest in REMIC V and the Class R-V Interest shall be designated as the sole class of Residual Interest in REMIC V. The Class CE Certificates V, and (vi) the REMIC VI Regular Interest IO shall be designated as the Regular Interests Interest in REMIC VI and the Class R-VI Interest shall be designated as the sole class of Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "“interests" ” in any Trust REMIC (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests, the REMIC III Regular Interests and the interests Regular Interests represented by the Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return (including Form 8811) or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued, copies of which forms and returns shall promptly be furnished by the Trustee to the NIMS Insurer. For the purposes of the REMIC election in respect of REMIC I1, the REMIC I 1 Regular Interests shall be designated as the Regular Interests in REMIC I 1 and the Class R-I R-1 Interest shall be designated as the Residual Interest in REMIC I. 1. For the purposes of the REMIC election in respect of REMIC 2, the REMIC 2 Regular Interests shall be designated as the Regular Interests in REMIC 2 and the Class R-2 Interest shall be designated as the Residual Interest in REMIC 2. The REMIC 3 Regular Interests shall be designated as the Regular Interests in REMIC 3 and the Class A R-3 Interest shall be designated as the Residual Interest in REMIC 3. For the purposes of the REMIC election in respect of REMIC 4, (i) the Regular Certificates (other than the Class C Certificates, the Class M-1 Swap IO Certificates and the Class M-2 P Certificates) and the REMIC 4 Regular Interests shall be designated as the Regular Interests in REMIC 4 and (ii) the Class R-4 Interest shall be designated as the Residual Interest in REMIC 4. For the purposes of the REMIC election in respect of REMIC CX, the Class C Certificates shall be designated as the Regular Interests in REMIC II CX and the Class R-II CX Interest shall be designated as the Residual Interest in REMIC IICX. The For the purposes of the REMIC election in respect of REMIC PX, the Class M-3 P Certificates shall be designated as the Regular Interests in REMIC III PX and the Class R-III PX Interest shall be designated as the Residual Interest in REMIC IIIPX. The For the purposes of the REMIC election in respect of REMIC SwapX, the Class M-4 Swap IO Certificates shall be designated as the Regular Interests in REMIC IV SwapX and the Class R-IV SwapX Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. SwapX. The Trustee shall not permit the creation of any "interests" in any Trust REMIC 1, REMIC 2, REMIC 3, REMIC 4, REMIC CX, REMIC SwapX or REMIC PX (within the meaning of Section 860G of the Code) other than the REMIC I 1 Regular Interests, the REMIC 2 Regular Interests, the REMIC 3 Regular Interests, the REMIC 4 Regular Interests and the interests represented by the Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return (including Form 8811) or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued, copies of which forms and returns shall promptly be furnished by the Trustee to the NIMS Insurer and the Class I-A4 Insurer. For the purposes of the REMIC election in respect of REMIC I1, the REMIC I 1 Regular Interests shall be designated as the Regular Interests in REMIC I 1 and the Class R-I R-1 Interest shall be designated as the Residual Interest in REMIC I. 1. For the purposes of the REMIC election in respect of REMIC 2, the REMIC 2 Regular Interests shall be designated as the Regular Interests in REMIC 2 and the Class R-2 Interest shall be designated as the Residual Interest in REMIC 2. The REMIC 3 Regular Interests shall be designated as the Regular Interests in REMIC 3 and the Class A R-3 Interest shall be designated as the Residual Interest in REMIC 3. For the purposes of the REMIC election in respect of REMIC 4, (i) the Regular Certificates (other than the Class C Certificates, the Class M-1 Swap IO Certificates and the Class M-2 P Certificates) and the REMIC 4 Regular Interests shall be designated as the Regular Interests in REMIC 4 and (ii) the Class R-4 Interest shall be designated as the Residual Interest in REMIC 4. For the purposes of the REMIC election in respect of REMIC CX, the Class C Certificates shall be designated as the Regular Interests in REMIC II CX and the Class R-II CX Interest shall be designated as the Residual Interest in REMIC IICX. The For the purposes of the REMIC election in respect of REMIC PX, the Class M-3 P Certificates shall be designated as the Regular Interests in REMIC III PX and the Class R-III PX Interest shall be designated as the Residual Interest in REMIC IIIPX. The For the purposes of the REMIC election in respect of REMIC SwapX, the Class M-4 Certificates Swap IO Upper-Tier Interest shall be designated as the Regular Interests in REMIC IV SwapX and the Class R-IV SwapX Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. SwapX. The Trustee shall not permit the creation of any "“interests" ” in any Trust REMIC 1, REMIC 2, REMIC 3, REMIC 4, REMIC CX, REMIC SwapX or REMIC PX (within the meaning of Section 860G of the Code) other than the REMIC I 1 Regular Interests, the REMIC 2 Regular Interests, the REMIC 3 Regular Interests, the REMIC 4 Regular Interests and the interests represented by the Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Trustee Paying Agent to treat the segregated pool of assets consisting of the Mortgage Loans (other than the Regal Cinema Eagan Loan and other than Excess Inxxxxxt payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Accounts, the Interest Reserve Account, the Distribution Account and the Reserve Account, the Insurance Policies and any related amounts REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing allocable to a Serviced Companion Loan. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For purposes of such election, the REMIC I Regular Interests shall each be designated as a separate class of "regular interests" in REMIC I and the REMIC I Residual Interest (represented by the Class R-I Certificates) shall be designated as the sole class of "residual interests" in REMIC I. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the Regal Cinema Eagan Loan, such amounts with respexx xxereto as shall from time to time be held in the related Certificate Account, the Interest Reserve Account, the RCE Loan REMIC Distribution Account and the Reserve Account, the Insurance Policies and any related amounts REO Account and any related REO Properties as a REMIC (the "RCE Loan REMIC") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC I Interests are issued. For purposes of such election, the RCE Loan REMIC Regular Interest shall be designated as a separate class of "regular interests" in the RCE Loan REMIC and the RCE Loan REMIC Residual Interest (represented by the Class R-I Certificates) shall be designated as the sole class of "residual interests" in the RCE Loan REMIC. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests and the RCE Loan REMIC Regular Interest as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I II Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the Regular Interests "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole class of the "residual interests" in REMIC II. The An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class M-3 A-1, Class A-1A, Class A-2, Class A-3, Class A-4, Class A-1A, Class A-M, Class A-J, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O, Class P and Class X Certificates shall be designated as Regular Interests the "regular interests" in REMIC III and the Class R-III Interest Certificates shall be designated as the Residual Interest sole class of "residual interests" in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Paying Agent shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests Interests, the RCE Loan REMIC Regular Interest, the REMIC II Regular Interests, the REMIC Regular Certificates and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Trustee to treat the segregated pool of assets consisting of the REMIC Mortgage Loans, such amounts as shall from time to time be held in the Collection Account and the Distribution Account in respect thereof (other than any amounts attributable to Non-REMIC Assets or Non-REMIC Fees), the Insurance Policies (to the extent related to the REMIC Mortgage Loans) and any REO Properties acquired in connection with servicing a REMIC Mortgage Loan as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the forty REMIC I Regular Interests shall be (each of which corresponds to and represents beneficial ownership of a separate REMIC Mortgage Loan) each is designated as the Regular Interests a separate class of "regular interests" in REMIC I and the Class R-I Interest shall be is designated as the Residual Interest sole class of "residual interests" in REMIC I. The An election will be made by the Trustee to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, each of the REMIC II Regular Interests (consisting of the Class A CertificatesA-1A Regular Interests, the Class M-1 Certificates A-1B Regular Interests, the Class A-2 Regular Interests, the Class B Regular Interests, the Class C Regular Interests, the Class D Regular Interests, the Class E Regular Interests, the Class F Regular Interests, the Class G Regular Interests, the Class H Regular Interests, the Class J Regular Interests, the Class K Regular Interests and the Class M-2 Certificates shall be L Regular Interests) is designated as the Regular Interests a separate class of "regular interests" in REMIC II and the Class R-II Interest shall be is designated as the Residual Interest sole class of "residual interests" in REMIC II. The An election will be made by the Trustee to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class M-3 A-1A, Class X-0X, Xxxxx X-0, Class IO, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K and Class L Certificates shall be are designated as Regular Interests the "regular interests" in REMIC III and the Class R-III Interest shall be is designated as the Residual Interest sole class of "residual interests" in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV R-I Interest, the Class R-II Interest and the Class R-IV III Interest initially shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and represented by the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VIIR Certificate. The Trustee shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests and the interests represented evidenced by the CertificatesREMIC III Certificates and the Class R Certificate.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Trustee on behalf of the Trust to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Collection Account and the Distribution Account, the Insurance Policies and any REO Properties and any other assets constituting REMIC I (as set forth on the definition of REMIC I) as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the sole class of "residual interests" in REMIC I. An election will be made by the Trustee on behalf of REMIC II to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole class of "residual interests" in REMIC II. The 147 An election will be made by the Trustee on behalf of REMIC III to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class M-3 A-1, Class A-2, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class L, Class M, Class N Certificates and each Component Interest of the Class X Certificates shall be designated as Regular Interests the "regular interests" in REMIC III and the Class R-III Interest Certificates shall be designated as the Residual Interest sole class of "residual interests" in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Treasury regulation Section 860G 1.860D-1(b)(1)) in any of the Code) REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests and the interests represented evidenced by the Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Accounts, the Interest Reserve Accounts, the Distribution Account and the Reserve Account, the Insurance Policies and any related amounts REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the sole class of "residual interests" in REMIC I. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole class of the "residual interests" in REMIC II. The An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class M-3 Certificates A-1, Class A-2, Class A-3, Class A-4, Class A-AB, Class A-5, Class A-1A, Class A-J, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O, Class P, Class X-1, Class X-2 and Class X-Y Certificates, shall be designated as Regular Interests the "regular interests" in REMIC III and the Class R-III Interest Certificates shall be designated as the Residual Interest sole class of "residual interests" in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Paying Agent shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests Interests, the REMIC II Regular Interests, the REMIC III Regular Certificates and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Accounts, the Interest Reserve Accounts, the Distribution Account and the Reserve Account, the Insurance Policies and any related amounts REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC I Interests are issued. For purposes of such election, the REMIC I Regular Interests shall each be designated as a separate class of "regular interests" in REMIC I and the Class [R-I] Certificates shall be designated as the sole class of "residual interests" in REMIC I. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I II Regular Interests shall be designated as the Regular Interests "regular interests" in REMIC I II and the Class [R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 II] Certificates shall be designated as the sole class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II III Certificates are issued. For purposes of such election, the Class [A-1], Class [A-1A], Class [A-2], Class [A-3-1], Class [A-3-2], Class [A-AB], Class [A-4A], Class [A-4B], Class [A-1A], Class [A-J], Class [B], Class [C], Class [D], Class [E], Class [F], Class [G], Class [H], Class [J], Class [K], Class [L], Class [M], Class [N], Class [O], Class [P], Class [X-1], Class [X-2] and Class [X-Y] Certificates and the Class RA-3-II Interest 1FL Regular Interest, shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests "regular interests" in REMIC III and the Class [R-III Interest III] Certificates shall be designated as the Residual Interest sole class of "residual interests" in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Paying Agent shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account, the Insurance Policies and any REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the Regular Interests sole Class of "residual interests" in REMIC II I. The Trustee and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Paying Agent shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests and the interests represented Residual Certificates. An election will be made by the CertificatesPaying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class R-II Certificates shall be designated as the sole Class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class A-1, Class A-2, Class X-1 (each Class X-1 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class X-2 (each Class X-2 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N and Class O Certificates shall be designated as the "regular interests" in REMIC III and the Class R-III Certificates shall be designated as the sole Class of "residual interests" in REMIC III.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Each such Such election will be made by the Trust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I-A, the REMIC I I-A Regular Interests shall be designated as the Regular Interest in REMIC I-A and the Class R-IA Residual Interest shall be designated as the Residual Interests in REMIC I-A. For the purposes of the REMIC election in respect of REMIC I-B, the Group 1 Certificates (other than the Class I-R Certificates) shall be designated as the Regular Interests in REMIC I-B and the Class R-IB Residual Interest shall be designated as the Residual Interest in REMIC I-B. For the purposes of the REMIC election in respect of REMIC II-A, the REMIC II-A Regular Interests shall be designated as the Regular Interests in REMIC I II-A and the Class R-I Interest shall be designated as the IIA Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The -A. For the purposes of the REMIC election in respect of REMIC II-B, the Group 2 Certificates (other than the Class M-3 Certificates 2-R Certificates) shall be designated as the Regular Interests in REMIC III II-B and the Class R-III IIB Residual Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates II-B. Neither the Trustee nor the Trust Administrator shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "“interests" ” in any Trust REMIC I-B or REMIC II-B (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests Group 1 Certificates and the interests represented Group 2 Certificates. The Trustee shall elect to treat each REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Such election will be made by the CertificatesTrust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued.

REMIC Administration. (a) The Trustee Trust Administrator shall elect to treat each Trust REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Each such Such election will be made by the Trust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I, the REMIC I Regular Interests shall be designated as the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Floating Rate Certificates (exclusive of any right to receive distributions from or obligation to make payments to the Net WAC Rate Carryover Reserve Account in respect of the Net WAC Rate Carryover Amount, the Reserve Fund, the Cap Account or the Swap Account), the Class M-3 Certificates CE Interest, the Class IO Interest and the Class P Interest shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 CE Certificates (exclusive of any right to receive distributions from or obligation to make payments to the Net WAC Rate Carryover Reserve Account in respect of the Net WAC Rate Carryover Amount or the Swap Account) shall be designated as the Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 P Certificates shall be designated as the Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates SWAP IO Interest shall be designated as the Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates Neither the Trustee nor the Trust Administrator shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "“interests" ” in any Trust REMIC (within the meaning of Section 860G of the Code) other than the REMIC I Regular Interests and the interests represented by the Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Account, the Class A-4FL Floating Rate Account, the Class A-MFL Floating Rate Account and the Interest Reserve Account, the Reserve Account and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Mortgage Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the sole Class of "residual interests" in REMIC I. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class R-II Certificates shall be designated as the sole Class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates, the Class A-4FL Regular Interest and the Class A-MFL Regular Interest are issued. For purposes of such election, the Class A-1, Class A-1A, Class A-2, Class A-3, Class A-4, Class A-J, Class X-1, Class X-2, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O and Class P Certificates and the Class A-4FL Regular Interest and the Class A-MFL Regular Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests "regular interests" in REMIC III and the Class R-III Interest Certificates shall be designated as the Residual Interest sole Class of "residual interests" in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Paying Agent shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the cclxxxviii REMIC I Regular Interests Interests, the REMIC II Regular Interests, the REMIC III Regular Certificates, the Class A-4FL Regular Interest, the Class A-MFL Regular Interest and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account, the Insurance Policies and any REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note and the Xxxx Xxxxx Companion Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the Regular Interests sole Class of "residual interests" in REMIC II I. The Trustee and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Paying Agent shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests and the interests represented Residual Certificates. An election will be made by the CertificatesPaying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class R-II Certificates shall be designated as the sole Class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class A-1, Class A-2, Class X-1 (each Class X-1 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class X-2 (each Class X-2 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N and Class O Certificates shall be designated as the "regular interests" in REMIC III and the Class R-III Certificates shall be designated as the sole Class of "residual interests" in REMIC III.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account, the Insurance Policies and any REO Properties as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as a separate class of "regular interests" in the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the Regular Interests sole class of "residual interests" in the REMIC II I. The Trustee and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Paying Agent shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I Regular Interests Interests, the REMIC II Regular Interests, the REMIC Regular Certificates and the interests represented Residual Certificates. An election will be made by the CertificatesPaying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interest is issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class R-II Certificates shall be designated as the sole class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class A-1, Class A-2, Class A-3, Class A-4, Class X-1, Class X-2, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M and Class N Certificates shall be designated as the "regular interests" in REMIC III and the Class R-III Certificates shall be designated as the sole class of "residual interests" in REMIC III.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account, the Insurance Policies and any REO Properties as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as a separate class of "regular interests" in the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the Regular Interests sole class of "residual interests" in the REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. I. The Trustee shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I Regular Interests Interests, the REMIC II Regular Interests, the REMIC Regular Certificates and the interests represented Residual Certificates. An election will be made by the CertificatesTrustee to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interest is issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class R-II Certificates shall be designated as the sole class of the "residual interests" in REMIC II. An election will be made by the Trustee to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC IV Certificates are issued. For purposes of such election, the Class X-0, Xxxxx X-0, Class X, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O and Class P Certificates shall be designated as the "regular interests" in REMIC III and the Class R-III Certificates shall be designated as the sole class of "residual interests" in REMIC III.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Trustee Paying Agent to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Accounts, the Interest Reserve Account, the Distribution Account and the Reserve Account, the Insurance Policies and any related amounts REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing allocable to a Serviced Companion Loan. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the sole class of "residual interests" in REMIC I. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole class of the "residual interests" in REMIC II. The An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC Regular Certificates and the Floating Rate Regular Interests are issued. For purposes of such election, the Class M-3 A-1, Class A-1A, Class A-2, Class A-3, Class A-4, Class A-M, Class A-MA, Class A-J, Class A-JA, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O, Class P, Class Q, Class S, Class X-1 and Class X-2 Certificates and the Class A-MFL and Class A-JFL Regular Interests shall be designated as Regular Interests the "regular interests" in REMIC III and the Class R-III Interest Certificates shall be designated as the Residual Interest sole class of "residual interests" in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Paying Agent shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC Regular Certificates, the Floating Rate Regular Interests and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Trustee on behalf of the Trust to treat the segregated pool of assets consisting of the Mortgage Loans (other than the right to Excess Interest in respect of the Hyper-Amortization Loans), such amounts as shall from time to time be held in the Collection Account and the Distribution Account in respect thereof, the Insurance Policies and any REO Properties and any other assets constituting REMIC I (as set forth on the definition of REMIC I) as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect such election, each of REMIC I, the REMIC I Regular Interests shall be designated as the Regular Interests a separate class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the sole class of "residual interests" in REMIC I. An election will be made by the Trustee on behalf of REMIC II to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole class of "residual interests" in REMIC II. The An election will be made by the Trustee on behalf of REMIC III to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code. Such election 158 will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class M-3 A-1, Class A-2, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, and Class N Certificates, the Class O Regular Interest represented by the Class O Certificates, and each Component Interest of the Class X Certificates shall be designated as Regular Interests the "regular interests" in REMIC III and the Class R-III Interest Certificates shall be designated as the Residual Interest sole class of "residual interests" in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Treasury regulation Section 860G 1.860D-1(b)(1)) in any of the Code) REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests and the interests represented evidenced by the Certificates.

REMIC Administration. (a) The Trustee Paying Agent shall elect make elections or cause elections to be made to treat each Trust of the Loan REMIC, the Lower-Tier REMIC and the Upper-Tier REMIC as a REMIC under the Code and, if necessary, under applicable state lawApplicable State and Local Tax Law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Uncertificated Lower-Tier Interests and the Certificates are issued. For the purposes of the REMIC election in respect of REMIC Ithe Upper-Tier REMIC, each Class of the Regular Certificates, the Class BM Certificates and the Class AC Certificates shall be designated as the "regular interests" (in the case of the Class NR Certificates, exclusive of the portion thereof, representing the right to Excess Interest and Amounts in the Excess Interest Distribution Account) and the Class R Certificates shall be designated as the sole class of "residual interests" in the Upper-Tier REMIC. For purposes of the REMIC I election in respect of the Lower-Tier REMIC, each Class of Uncertificated Lower-Tier Interests shall be designated as the "regular interests" and the Class LR Certificates shall be designated as the sole class of "residual interests" in the Lower-Tier REMIC. For purposes of the REMIC election in respect of the Loan REMIC, each Class of Loan REMIC Regular Interests shall be designated as the Regular Interests in REMIC I "regular interests" and the Loan REMIC Residual Interest, represented by the Class R-I Interest LR Certificates, shall be designated as the Residual Interest sole class of "residual interests" in REMIC I. The Class A Certificatesthe Loan REMIC. None of the Special Servicer, the Class M-1 Certificates and Servicer, the Class M-2 Certificates shall be designated as Paying Agent nor the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in the Loan REMIC, the Lower-Tier REMIC or the Upper-Tier REMIC other than the REMIC I Regular Interests and the interests represented by the Certificatesforegoing interests.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans (other than Excess Interest payable thereon), such amounts with respect thereto as shall from time to time be held in the Certificate Account, the Interest Reserve Account, the Reserve Account and the Distribution Account (exclusive of the Excess Interest Sub-account), the Insurance Policies and any related amounts in the REO Account and any related REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note or Serviced Companion Mortgage Loan. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the sole Class of "residual interests" in REMIC I. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class R-II Interest Certificates shall be designated as the Residual Interest sole Class of the "residual interests" in REMIC II. The An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class M-3 A-1, Class X-0, Xxxxx X-0, Class A-AB, Class A-4, Class A-M, Class A-J, Class X, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M, Class N, Class O, Class MMA-NA, Class MMB-NA and Class P Certificates (but other than the Class P Grantor Trust Interest) shall be designated as Regular Interests the "regular interests" in REMIC III and the Class R-III Interest Certificates shall be designated as the Residual Interest sole Class of "residual interests" in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV Trustee and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Paying Agent shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMIC Pools other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests and the interests represented by the Residual Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account, the Insurance Policies and any REO Properties as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as a separate class of "regular interests" in the Regular Interests in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the Regular Interests sole class of "residual interests" in the REMIC II I. The Trustee and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Paying Agent shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I, REMIC II, REMIC III and REMIC IV Regular Interests and the Residual Certificates. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interest is issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the interests represented Class R-II Certificates shall be designated as the sole class of the "residual interests" in REMIC II. An election will be made by the CertificatesPaying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interest is issued. For the purposes of such election, the REMIC III Regular Interests shall be designated as the "regular interests" in REMIC III and the Class R-III Certificates shall be designated as the sole class of the "residual interests" in REMIC III. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC III Regular Interests as a REMIC under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC IV Certificates are issued. For purposes of such election, the Class X-0, Xxxxx X-0, Class X, Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L and Class M Certificates shall be designated as the "regular interests" in REMIC IV and the Class R-IV Certificates shall be designated as the sole class of "residual interests" in REMIC IV.

REMIC Administration. (a) The Trustee Paying Agent shall elect make elections or cause elections to be made to treat each Trust of the Loan REMIC, the Lower-Tier REMIC and the Upper-Tier REMIC as a REMIC under the Code and, if necessary, under applicable state lawApplicable State and Local Tax Law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Uncertificated Lower-Tier Interests and the Certificates are issued. For the purposes of the REMIC election in respect of REMIC Ithe Upper-Tier REMIC, each Class of the Regular Certificates and the Class RP Certificates shall be designated as the "regular interests" (in the case of the Class NR Certificates, exclusive of the portion thereof, representing the right to Excess Interest and amounts in the Excess Interest Distribution Account) and the Class R Certificates shall be designated as the sole class of "residual interests" in the Upper-Tier REMIC. For purposes of the REMIC I election in respect of the Lower-Tier REMIC, each Class of Uncertificated Lower-Tier Interests shall be designated as the "regular interests" and the Class LR Certificates shall be designated as the sole class of "residual interests" in the Lower-Tier REMIC. For purposes of the REMIC election in respect of the Loan REMIC, each Class of Loan REMIC Regular Interests shall be designated as the Regular Interests in REMIC I "regular interests" and the Loan REMIC Residual Interest, represented by the Class R-I Interest LR Certificates, shall be designated as the Residual Interest sole class of "residual interests" in REMIC I. The Class A Certificatesthe Loan REMIC. None of the Special Servicer, the Class M-1 Certificates and Master Servicer, the Class M-2 Certificates shall be designated as Paying Agent nor the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in the Loan REMIC, the Lower-Tier REMIC or the Upper-Tier REMIC other than the REMIC I Regular Interests and the interests represented by the Certificatesforegoing interests.

REMIC Administration. (a) The Trustee Trust Administrator shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return (including Form 8811) or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued, copies of which forms and returns shall promptly be furnished by the Trust Administrator to the NIMS Insurer and the Certificate Insurer. For the purposes of the REMIC election in respect of REMIC I1, the REMIC I 1 Regular Interests shall be designated as the Regular Interests in REMIC I 1 and the Class R-I R-1 Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates1. For the purposes of the REMIC election in respect of REMIC 2, the REMIC 2 Regular Interests shall be designated as the Regular Interests in REMIC 2 and the Class M-1 R-2 Interest shall be designated as the Residual Interest in REMIC 2. For the purposes of the REMIC election in respect of REMIC 3, the REMIC 3 Regular Interests shall be designated as the Regular Interests in REMIC 3 and the Class R-3 Interest shall be designated as the Residual Interest in REMIC 3. For the purposes of the REMIC election in respect of REMIC 4, (i) the Regular Certificates (other than the Class C Certificates and the Class M-2 P Certificates) and the REMIC 4 Regular Interests shall be designated as the Regular Interests in REMIC 4 and (ii) the Class R-4 Interest shall be designated as the Residual Interest in REMIC 4. For the purposes of the REMIC election in respect of REMIC CX, the Class C Certificates shall be designated as the Regular Interests in REMIC II CX and the Class R-II CX Interest shall be designated as the Residual Interest in REMIC IICX. The For purposes of the REMIC election in respect of REMIC PX, the Class M-3 P Certificates shall be designated as the Regular Interests in REMIC III PX and the Class R-III PX Interest shall be designated as the Residual Interest in REMIC IIIPX. The Class M-4 Certificates Neither the Trustee nor the Trust Administrator shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "interests" in any Trust REMIC 1, REMIC 2, REMIC 3, REMIC 4, REMIC CX or REMIC PX (within the meaning of Section 860G of the Code) other than the REMIC 1 Regular Interests, the REMIC 2 Regular Interests, the REMIC 3 Regular Interests, the REMIC 4 Group I Regular Interests, the REMIC 4 Group II Regular Interests, the REMIC 4 Regular Interests and the interests represented by the Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return (including Form 8811) or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued, copies of which forms and returns shall promptly be furnished by the Trustee to the NIMS Insurer. For the purposes of the REMIC election in respect of REMIC I1, the REMIC I 1 Regular Interests shall be designated as the Regular Interests in REMIC I 1 and the Class R-I R-1 Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates1. For the purposes of the REMIC election in respect of REMIC 2, the REMIC 2 Regular Interests shall be designated as the Regular Interests in REMIC 2 and the Class M-1 R-2 Interest shall be designated as the Residual Interest in REMIC 2. For the purposes of the REMIC election in respect of REMIC 3, the REMIC 3 Regular Interests shall be designated as the Regular Interests in REMIC 3 and the Class R-3 Interest shall be designated as the Residual Interest in REMIC 3. For the purposes of the REMIC election in respect of REMIC 4, (i) the Regular Certificates (other than the Class C Certificates and the Class M-2 P Certificates) and the REMIC 4 Regular Interests shall be designated as the Regular Interests in REMIC 4 and (ii) the Class R-4 Interest shall be designated as the Residual Interest in REMIC 4. For the purposes of the REMIC election in respect of REMIC CX, the Class C Certificates shall be designated as the Regular Interests in REMIC II CX and the Class R-II CX Interest shall be designated as the Residual Interest in REMIC IICX. The For purposes of the REMIC election in respect of REMIC PX, the Class M-3 P Certificates shall be designated as the Regular Interests in REMIC III PX and the Class R-III PX Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VIIPX. The Trustee shall not permit the creation of any "interests" in any Trust REMIC 1, REMIC 2, REMIC 3, REMIC 4, REMIC CX or REMIC PX (within the meaning of Section 860G of the Code) other than the REMIC I 1 Regular Interests, the REMIC 2 Regular Interests, the REMIC 3 Regular Interests, the REMIC 4 Regular Interests and the interests represented by the Certificates.

REMIC Administration. (a) The Trustee Securities Administrator shall elect make an election to treat each Trust REMIC portions the Issuing Entity as a REMIC four REMICs under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return (including Form 8811) or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election elections in respect of the Trust Fund, (i) the REMIC I1 Regular Interests will represent the “regular interests” in REMIC 1, the Class R-1 Interest will constitute the sole class of “residual interests” in REMIC I 1, (ii) the REMIC 2 Regular Interests shall be designated as will represent the Regular Interests “regular interests” in REMIC I 2, the Class R-2 Interest will constitute the sole class of “residual interests” in REMIC 2, (iii) the Class A Certificates and Class M Certificates (exclusive of the right to receive Net Rate Carryover and the obligation to make payments to the Swap Supplemental Interest Trust), the Class C Interest, Class P Interest and Class IO Interest will represent the “regular interests” in REMIC 3, the Class R-3 Interest will constitute the sole Class of “residual interests” in REMIC 3, (iv) the Class C Certificates (exclusive of the obligation to pay Net Rate Carryover and the obligation to make payments to the Swap Supplemental Interest Trust) will represent the “regular interests” in REMIC 4, the Class R-4 Interest will constitute the sole Class of “residual interests” in REMIC 4, (v) the Class P Certificates will represent the “regular interests” in REMIC 5, the Class R-5 Interest will constitute the sole Class of “residual interests” in REMIC 5, (vi) REMIC 6 Regular Interest IO will represent the “regular interests” in REMIC 6, the Class R-6 Interest will constitute the sole Class of “residual interests” in REMIC 6, and (vii) the Class R Certificates will evidence ownership of the Class R-1 Interest, the Class R-2 Interest and the Class R-3 Interest and the Class R-I Interest shall be designated as X Certificates will evidence ownership of the Residual Interest in REMIC I. The Class A CertificatesR-4 Interest, the Class M-1 Certificates R-5 Interest and the Class M-2 Certificates shall be designated as R-6 Interest. Neither the Regular Interests in REMIC II and Securities Administrator nor the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "“interests" in any Trust REMIC ” (within the meaning of Section 860G of the Code) in any REMIC created hereunder other than the REMIC I 1 Regular Interests Interests, the REMIC 2 Regular Interests, the Class C Interest, the Class P Interest, the Class IO Interest and the interests represented by Certificates. The Securities Administrator will apply for an Employee Identification Number from the CertificatesIRS via form SS-4 or any other acceptable method for each Trust REMIC.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Each such Such election will be made by the Trust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I-A, the REMIC I I-A Regular Interests shall be designated as the Regular Interests in REMIC I I-A and the Class R-I IA Residual Interest shall be designated as the Residual Interests in REMIC I-A. For the purposes of the REMIC election in respect of REMIC I-B, the Group 1 Certificates (other than the Class 1-R Certificates) shall be designated as the Regular Interests in REMIC I-B and the Class R-IB Residual Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, I-B. Neither the Class M-1 Certificates and Trustee nor the Class M-2 Certificates Trust Administrator shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "“interests" ” in any Trust REMIC I-A or REMIC I-B (within the meaning of Section 860G of the Code) other than the REMIC I I-A Regular Interests and the interests represented Group 1 Certificates. For the purposes of the REMIC election in respect of REMIC II-A, the REMIC II-A Regular Interests shall be designated as the Regular Interests in REMIC II-A and the Class R-IIA Residual Interest shall be designated as the Residual Interests in REMIC II-A. For the purposes of the REMIC election in respect of REMIC II-B, the Group 2 Certificates (other than the Class 2-R Certificates) shall be designated as the Regular Interests in REMIC II-B and the Class R-IIB Residual Interest shall be designated as the Residual Interest in REMIC II-B. Neither the Trustee nor the Trust Administrator shall permit the creation of any “interests” in REMIC II-A or REMIC II-B (within the meaning of Section 860G of the Code) other than the REMIC II-A Regular Interests and the Group 2 Certificates. For the purposes of the REMIC election in respect of REMIC II-C, the Group 2 Certificates (other than the Class 2-R Certificates) shall be designated as the Regular Interests in REMIC II-C and the Class R-IIC Residual Interest shall be designated as the Residual Interest in REMIC II-C. The Trustee shall elect to treat each REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Such election will be made by the CertificatesTrust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return (including Form 8811) or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued, copies of which forms and returns shall promptly be furnished by the Trustee to the NIMS Insurer and the Certificate Insurer. For the purposes of the REMIC election in respect of REMIC I1, the REMIC I 1 Regular Interests shall be designated as the Regular Interests in REMIC I 1 and the Class R-I R-1 Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates1. For the purposes of the REMIC election in respect of REMIC 2, the REMIC 2 Regular Interests shall be designated as the Regular Interests in REMIC 2 and the Class M-1 R-2 Interest shall be designated as the Residual Interest in REMIC 2. For the purposes of the REMIC election in respect of REMIC 3, the REMIC 3 Regular Interests shall be designated as the Regular Interests in REMIC 3 and the Class R-3 Interest shall be designated as the Residual Interest in REMIC 3. For the purposes of the REMIC election in respect of REMIC 4, (i) the Regular Certificates (other than the 178 Class C Certificates and the Class M-2 P Certificates) and the REMIC 4 Regular Interests shall be designated as the Regular Interests in REMIC 4 and (ii) the Class R-4 Interest shall be designated as the Residual Interest in REMIC 4. For the purposes of the REMIC election in respect of REMIC CX, the Class C Certificates shall be designated as the Regular Interests in REMIC II CX and the Class R-II CX Interest shall be designated as the Residual Interest in REMIC IICX. The For purposes of the REMIC election in respect of REMIC PX, the Class M-3 P Certificates shall be designated as the Regular Interests in REMIC III PX and the Class R-III PX Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VIIPX. The Trustee shall not permit the creation of any "interests" in any Trust REMIC 1, REMIC 2, REMIC 3, REMIC 4, REMIC CX or REMIC PX (within the meaning of Section 860G of the Code) other than the REMIC 1 Regular Interests, the REMIC 2 Regular Interests, the REMIC 3 Regular Interests, the REMIC 4 Group I Regular Interests, the REMIC 4 Group II Regular Interests, the REMIC 4 Regular Interests and the interests represented by the Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Each such Such election will be made by the Trust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I-A, the REMIC I I-A Regular Interests shall be designated as the Regular Interests in REMIC I I-A and the Class R-I IA Residual Interest shall be designated as the Residual Interests in REMIC I-A. For the purposes of the REMIC election in respect of REMIC I-B, the REMIC I-B Regular Interests shall be designated as the Regular Interests in REMIC I-B and the Class R-IB Residual Interest shall be designated as the Residual Interests in REMIC I-B. For the purposes of the REMIC election in respect of REMIC I-C, the Group 1 Certificates (other than the Class 1-R Certificates) shall be designated as the Regular Interests in REMIC I-C and the Class R-IC Residual Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, I-C. Neither the Class M-1 Certificates and Trustee nor the Class M-2 Certificates Trust Administrator shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "“interests" ” in any Trust REMIC I-A, REMIC I-B or REMIC I-C (within the meaning of Section 860G of the Code) other than the REMIC I I-A Regular Interests, REMIC I-B Regular Interests and the interests represented Group 1 Certificates. For the purposes of the REMIC election in respect of REMIC II-A, the REMIC II-A Regular Interests shall be designated as the Regular Interests in REMIC II-A and the Class R-IIA Residual Interest shall be designated as the Residual Interests in REMIC II-A. For the purposes of the REMIC election in respect of REMIC II-B, the REMIC II-B Regular Interests shall be designated as the Regular Interests in REMIC II-B and the Class R-IIB Residual Interest shall be designated as the Residual Interests in REMIC II-B. For the purposes of the REMIC election in respect of REMIC II-C, the Group 2 Certificates (other than the Class 2-R Certificates) shall be designated as the Regular Interests in REMIC II-C and the Class R-IIC Residual Interest shall be designated as the Residual Interest in REMIC II-C. Neither the Trustee nor the Trust Administrator shall permit the creation of any “interests” in REMIC II-A, REMIC II-B or REMIC II-C (within the meaning of Section 860G of the Code) other than the REMIC II-A Regular Interests, REMIC II-B Regular Interests and the Group 2 Certificates. The Trustee shall elect to treat each REMIC created hereunder as a REMIC under the Code and, if necessary, under applicable state law. Such election will be made by the CertificatesTrust Administrator on behalf of the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such election will be made by the Trustee on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates are issued. For the purposes of the REMIC election in respect of REMIC I-A, the REMIC I I-A Regular Interests shall be designated as the Regular Interests in REMIC I I-A and the Class R-I Certificates shall be designated as the Residual Interest in REMIC I-A. For the purposes of the REMIC election in respect of REMIC I-B, the REMIC I-B Regular Interests shall be designated as the Regular Interests in REMIC I-B and the Class R-II Certificates shall be designated as the Residual Interest in REMIC I-B. For the purposes of the REMIC election in respect of REMIC I-C, the REMIC I-C Regular Interests shall be designated as the Regular Interests in REMIC I-C and the Class R-III Certificates Interest shall be designated as the Residual Interest in REMIC I. The Class A CertificatesI-C. For the purposes of the REMIC election in respect of REMIC II, the Class M-1 Certificates and the Class M-2 Certificates REMIC II Regular Interests shall be designated as the Regular Interests in REMIC II and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Group I Class M-3 A Certificates, the Group II Class A Certificates, the Group III Class A Certificates, each of the Mezzanine Certificates, the Class CE Certificates and the Class P Certificates (other than the right to receive amounts, if any, from the Net WAC Rate Carryover Reserve Accounts) shall be designated as the Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) other than the REMIC I I-A Regular Interests, the REMIC I-B Regular Interests, the REMIC I-C Regular Interests, the REMIC II Regular Interests and the interests represented by the Certificates.

REMIC Administration. (a) The Trustee shall elect to treat each Trust REMIC as a REMIC under the Code and, if necessary, under applicable state law. Each such An election will be made by the Paying Agent on behalf of the Trustee to treat the segregated pool of assets consisting of the Mortgage Loans, such amounts as shall from time to time be held in the Certificate Account and the Distribution Account, the Insurance Policies and any REO Properties as a REMIC ("REMIC I") under the Code, other than any portion of the foregoing amounts allocable to a B Note. Such elections will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the Certificates REMIC I Interests are issued. For the purposes of the REMIC election in respect of REMIC Isuch election, the REMIC I Regular Interests shall each be designated as the Regular Interests a separate Class of "regular interests" in REMIC I and the Class R-I Interest shall be designated as the Residual Interest in REMIC I. The Class A Certificates, the Class M-1 Certificates and the Class M-2 Certificates shall be designated as the Regular Interests sole Class of "residual interests" in REMIC II I. The Trustee and the Class R-II Interest shall be designated as the Residual Interest in REMIC II. The Class M-3 Certificates shall be designated as Regular Interests in REMIC III and the Class R-III Interest shall be designated as the Residual Interest in REMIC III. The Class M-4 Certificates shall be designated as Regular Interests in REMIC IV and the Class R-IV Interest shall be designated as the Residual Interest in REMIC IV. The Class M-5 Certificates shall be designated as Regular Interests in REMIC V and the Class R-V Interest shall be designated as the Residual Interest in REMIC V. The Class CE Certificates shall be designated as Regular Interests in REMIC VI and the Class R-VI Interest shall be designated as the Residual Interest in REMIC VI. The Class P Certificates shall be designated as Regular Interests in REMIC VII and the Class R-VII Interest shall be designated as the Residual Interest in REMIC VII. The Trustee Paying Agent shall not permit the creation of any "interests" in any Trust REMIC (within the meaning of Section 860G of the Code) in any of the REMICs other than the REMIC I Regular Interests, the REMIC II Regular Interests, the REMIC III Regular Interests and the interests represented Residual Certificates. An election will be made by the CertificatesPaying Agent to treat the segregated pool of assets consisting of the REMIC I Regular Interests as a REMIC ("REMIC II") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC II Interests are issued. For the purposes of such election, the REMIC II Regular Interests shall be designated as the "regular interests" in REMIC II and the Class R-II Certificates shall be designated as the sole Class of the "residual interests" in REMIC II. An election will be made by the Paying Agent to treat the segregated pool of assets consisting of the REMIC II Regular Interests as a REMIC ("REMIC III") under the Code. Such election will be made on Form 1066 or other appropriate federal tax or information return or any appropriate state return for the taxable year ending on the last day of the calendar year in which the REMIC III Certificates are issued. For purposes of such election, the Class A-1, Class A-2, Class X-1 (each Class X-1 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class X-2 (each Class X-2 Certificate representing multiple "regular interests" in REMIC III, as set forth in the Preliminary Statement), Class B, Class C, Class D, Class E, Class F, Class G, Class H, Class J, Class K, Class L, Class M and Class N Certificates shall be designated as the "regular interests" in REMIC III and the Class R-III Certificates shall be designated as the sole Class of " residual interests" in REMIC III.