("REITs") as described in "Certain Federal Income Tax Consequences" in the Base Offering Circular. Similarly, interest on the Regular Securities will be considered "interest on obliga- tions secured by mortgages on real property" for REITs. Residual Securities The Class RR Securities will represent the beneficial ownership of the Residual Interest in the Pooling REMIC and the beneficial ownership of the Residual Interest in the Issuing REMIC. The Residual Securities, i.e., the Class RR  Securities, generally will be treated as "residual interests" in a REMIC for domestic building and loan associations and as "real estate assets" for REITs,  as  described  in  "Certain  Federal  Income  Tax  Consequences"  in  the  Base  Offering Circular, but will not be treated as debt for federal income tax purposes. Instead, the Holders of the Residual Securities will be required to report, and will be taxed on, their pro rata shares of the taxable income or loss of the Trust REMICs, and these requirements will continue until there  are  no  outstanding  regular  interests  in  the  respective  Trust  REMICs.  Thus,  Residual Holders will have taxable income attributable to the Residual Securities even though they will not receive principal or interest distributions with respect to the Residual Securities, which could result in a negative after-tax return for the Residual Holders. It is not expected that the Pooling  REMIC  will  have  a  substantial  amount  of  taxable  income  or  loss  in  any  period. However, even though the Holders of the Class RR Securities are not entitled to any stated principal  or  interest  payments  on  the  Class  RR  Securities,  the  Issuing  REMIC  may  have substantial taxable income in certain periods, and offsetting tax losses may not occur until much later  periods.  Accordingly,  a  Holder  of  the  Class  RR  Securities  may  experience  substantial adverse  tax  timing  consequences.  Prospective  investors  are  urged  to  consult  their  own  tax advisors  and  consider  the  after-tax  effect  of  ownership  of  the  Residual  Securities  and  the suitability of the Residual Securities to their investment objectives. Prospective Holders of Residual Securities should be aware that, at issuance, based on the expected  prices  of  the  Regular  and  Residual  Securities  and  the  prepayment  assumption described above, the residual interests represented by the Residual Securities will be treated as "noneconomic residual interests" as that term is defined in Treasury regulations. OID  accruals  on  the  Underlying  SMBS  Securities  will  be  computed  using  the  same prepayment  assumption  as  set  forth  under  "Certain  Federal  Income  Tax  Consequences – Regular Securities" in this Supplement. MX Securities For a discussion of certain federal income tax consequences applicable to the MX Classes, see "Certain Federal Income Tax Consequences – Tax Treatment of MX Securities", "– Ex- changes of MX Classes and Regular Classes" and "– Taxation of Foreign Holders of REMIC Securities and MX Securities" in the Base Offering Circular. Investors should consult their own tax advisors in determining the federal, state, local  and  any  other  tax  consequences  to  them  of  the  purchase,  ownership  and disposition of the Securities. ERISA MATTERS Ginnie Mae guarantees distributions of principal and interest with respect to the Securities. The Ginnie Mae Guaranty is supported by the full faith and credit of the United States of America. The Regular and MX Securities will qualify as "guaranteed governmental mortgage pool certificates" within the meaning of a Department of Labor regulation, the effect of which is S-35