SECURITY GROUP 8 Sensitivity of Class IM to Prepayments Assumed Price 16.5%* PSA Prepayment Assumption Rates 165% 203% 400% 500% 521% 9.7% 9.7% 8.1% 1.6% 0.1% *  The price does not include accrued interest. Accrued interest has been added to the price in calculating the yields set forth in the table. **  Indicates that investors will suffer a loss of virtually all of their investment. CERTAIN FEDERAL INCOME TAX CONSEQUENCES The following tax discussion, when read in conjunction with the discussion of "Certain Federal  Income  Tax  Consequences"  in  the  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 Milbank, Tweed, Hadley & McCloy 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  DO,  EO  and  TO  Securities  are  Principal  Only  Securities.  Principal  Only Securities are treated for federal income tax purposes as having been issued with an amount of original issue discount ("OID") equal to the difference between their principal balance and their issue price. The Class IA, IB, IC, IG, IK, IM, IO, IS, IT, IX, JI, KI, MI, PS, SA, SC, SD, SE, SH, SI and SP Securities  are  "Interest  Weighted  Securities"  as  described  in  "Certain  Federal  Income  Tax Consequences – Tax Treatment of Regular Securities – Interest Weighted Securities and Non- VRDI Securities" in the 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 S-41