Common use of Tax Classification of the Excess Reserve Fund Account and the Supplemental Interest Trust Clause in Contracts

Tax Classification of the Excess Reserve Fund Account and the Supplemental Interest Trust. For federal income tax purposes, the Securities Administrator shall treat the Excess Reserve Fund Account and the Supplemental Interest Trust as beneficially owned by the holders of the Class X Certificates and shall treat such portion of the Trust Fund as a grantor trust, within the meaning of subpart E, Part I of subchapter J of the Code. The Securities Administrator shall treat the rights that each Class of LIBOR Certificates has to receive payments of Basis Risk Carryover Amounts from the Excess Reserve Fund Account as rights to receive payments under a notional principal contract written by the Class X Certificateholders in favor of each such Class and beneficially owned by each such Class through the grantor trust. Accordingly, each Class of Certificates (excluding the Class X, Class P and Class R Certificates) will be comprised of two components – an Upper Tier REMIC Regular Interest and an interest in a notional principal contract, and the Class X Certificates will be comprised of two components – an Upper Tier REMIC Regular Interest and an interest in the Excess Reserve Fund Account, subject to obligation to pay Basis Risk Carryover Amounts. The Securities Administrator shall allocate the issue price for a Class of Certificates among the respective components for purposes of determining the issue price of the Upper Tier REMIC Regular Interest component based on information received from the Depositor.

Tax Classification of the Excess Reserve Fund Account and the Supplemental Interest Trust. For federal income tax purposes, the Securities Administrator shall treat the Excess Reserve Fund Account and the Supplemental Interest Trust as beneficially owned by the holders of the Class X Certificates and shall treat such portion of the Trust Fund as a grantor trust, within the meaning of subpart E, Part I of subchapter J of the Code. The Securities Administrator shall treat the rights that each Class of LIBOR Certificates has to receive payments of Basis Risk Carryover Amounts from the Excess Reserve Fund Account as rights to receive payments under a notional principal contract written by the Class X Certificateholders in favor of each such Class and beneficially owned by each such Class through the grantor trust. Accordingly, each Class of Certificates (excluding the Class X, Class P and Class R Certificates) will be comprised of two components – - an Upper Tier REMIC Regular Interest and an interest in a notional principal contract, and the Class X Certificates will be comprised of two components – - an Upper Tier REMIC Regular Interest and an interest in the Excess Reserve Fund Account, subject to obligation to pay Basis Risk Carryover Amounts. The Securities Administrator shall allocate the issue price for a Class of Certificates among the respective components for purposes of determining the issue price of the Upper Tier REMIC Regular Interest component based on information received from the Depositor.

Tax Classification of the Excess Reserve Fund Account and the Supplemental Interest Trust. For federal income tax purposes, the Securities Administrator shall treat the [Excess Reserve Fund Account Account] and the Supplemental Interest Trust as beneficially owned by the holders of the Class X [X] Certificates and shall treat such portion of the Trust Fund as a grantor trust, within the meaning of subpart E, Part I of subchapter J of the Code. The Securities Administrator shall treat the rights that each Class of LIBOR Certificates has to receive payments of Basis Risk Carryover Amounts from the [Excess Reserve Fund Account Account] as rights to receive payments under a notional principal contract written by the Class X [X] Certificateholders in favor of each such Class and beneficially owned by each such Class through the grantor trust. Accordingly, each Class of Certificates (excluding the Class [X], Class P [P] and Class R [R] Certificates) will be comprised of two components – - an [Upper Tier Tier] REMIC Regular Interest and an interest in a notional principal contract, and the Class X [X] Certificates will be comprised of two components – - an [Upper Tier Tier] REMIC Regular Interest and an interest in the [Excess Reserve Fund Account], subject to obligation to pay Basis Risk Carryover Amounts. The Securities Administrator shall allocate the issue price for a Class of Certificates among the respective components for purposes of determining the issue price of the [Upper Tier Tier] REMIC Regular Interest component based on information received from the Depositor.