The information set forth in the following table was prepared on the basis of the Modeling Assumptions and the assumption that the purchase price of Class IO (expressed as a percentage of its original Class Notional Balance) plus accrued interest is as indicated in the table. The assumed purchase price is not necessarily that at which actual sales will occur. Sensitivity of Class IO to Prepayments Assumed Price 5.60100%* CPR Prepayment Assumption Rates 5% 15% 25% 40% 10.1% 7.3% 7.6% 9.3% *  The price does not include accrued interest. Accrued interest has been added to the price in calculating the yields set forth in the table. CERTAIN FEDERAL INCOME TAX CONSEQUENCES The following tax discussion, when read in conjunction with the discussion of "Certain Federal Income Tax Consequences" in the Multifamily Base Offering Circular, describes the material federal income tax considerations for investors in the Securities. However, these two tax  discussions  do  not  purport  to  deal  with  all  federal  tax  consequences  applicable  to  all categories of investors, some of which may be subject to special rules. U.S. Treasury Circular 230 Notice The discussion contained in this Supplement and the Base Offering Circular as to certain federal tax consequences is not intended or written to be used, and cannot be used, for the purpose of avoiding United States federal tax penalties. Such discussion is written  to  support  the  promotion  or  marketing  of  the  transactions  or  matters  ad- dressed in this Supplement and the Base Offering Circular. Each taxpayer to whom such transactions or matters are being promoted, marketed or recommended should seek advice based on its particular circumstances from an independent tax advisor. REMIC Elections In the opinion of Cleary Gottlieb Steen & Hamilton LLP, the Trust will constitute a Double REMIC Series for federal income tax purposes. Separate REMIC elections will be made for the Pooling REMIC and the Issuing REMIC. Regular Securities The Regular Securities will be treated as debt instruments issued by the Issuing REMIC for federal income tax purposes. Income on the Regular Securities must be reported under an accrual method of accounting. The Class IO Securities are "Interest Weighted Securities" as described in "Certain Federal Income Tax Consequences – Tax Treatment of Regular Securities – Interest Weighted Securi- ties  and  Non-VRDI  Securities"  in  the  Multifamily  Base  Offering  Circular.  Although  the  tax treatment  of  Interest  Weighted  Securities  is  not  entirely  certain,  Holders  of  the  Interest Weighted Securities should expect to accrue all income on these Securities (other than income attributable  to  market  discount  or  de  minimis  market  discount)  under  the  original  issue discount ("OID") rules based on the expected payments on these Securities at the prepayment assumption described below. S-26