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 related Trust REMICs, and these requirements will continue
until there are no outstanding regular interests in the respective Trust REMICs, even though the
Holders previously may have received full payment of their stated interest and principal. 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. 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 Trust REMICs 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 Certificates will be computed using the same prepayment
assumption as set forth under "Certain Federal Income Tax Consequences Regular Securi-
ties" in this Supplement.
The United States Department of the Treasury has recently issued temporary regulations
that may accelerate the time for withholding with respect to excess inclusions allocable to
foreign investors in certain types of pass-through entities that hold the Residual Securities. The
regulations are effective as to allocations of income on or after August 1, 2006. You should
consult your tax advisor concerning these regulations and their potential application to an
investment by you in the Residual Securities.
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
to provide that mortgage loans and participations therein underlying a "guaranteed governmen-
tal mortgage pool certificate" will not be considered assets of an employee benefit plan subject
to the Employee Retirement Income Security Act of 1974, as amended ("ERISA"), or subject to
section 4975 of the Code (each, a "Plan"), solely by reason of the Plan's purchase and holding
of that certificate.
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