The yields were calculated by:
1. determining the monthly discount rates that, when applied to the assumed streams of cash flows
to be paid on Class IO, would cause the discounted present value of the assumed streams of cash
flows to equal the assumed purchase price of that Class plus accrued interest, and
2. converting the monthly rates to corporate bond equivalent rates.
These calculations do not take into account variations that may occur in the interest rates at which
investors may be able to reinvest funds received by them as distributions on their Securities and
consequently do not purport to reflect the return on investment in any Class when those reinvestment
rates are considered.
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 5.57985%*
5%
15%
25%
40%
CPR Prepayment Assumption Rates
10.4%
11.3%
14.3%
19.4%
* 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 Multifamily 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 addressed in
this Supplement and the Multifamily 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.
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