Base Offering Circular – Multifamily 25 (c)  to prepare all information reports and returns required to be provided to Holders under federal or state tax provisions concerning REMICs, including Schedule Q to Form 1066, and to forward these reports and returns to the appropriate Holders; and (d) to pay when due, on behalf of the affected Trust REMIC or the Trust, the amount of any federal, state and local taxes imposed thereon, which amount generally will be paid from assets of the related Trust. Ginnie Mae does not guarantee the accuracy or timeliness of the tax administration and reporting. CERTAIN FEDERAL INCOME TAX CONSEQUENCES The following discussion, prepared by Ginnie Mae’s Legal Advisor, is a summary of the anticipated material federal income tax consequences of the purchase, ownership, and disposition of the Securities.  The summary is based upon laws, regulations, rulings, and decisions now in effect, all of which are subject to change.  The discussion does not purport to deal with the federal income tax consequences to all categories of investors, some of which may be subject to special rules.  The discussion focuses primarily on investors who will hold the Securities as “capital assets” (generally, property held for investment) within the meaning of section 1221 of the Code, although much of the discussion is applicable to other investors as well.  Investors should note that, although final regulations under the REMIC Provisions of the Code (the “REMIC Regulations”) have been issued by the U.S. Treasury, no currently effective regulations or other administrative guidance have been issued with respect to certain provisions of the Code that are or may be applicable to Holders, particularly the provisions dealing with market discount and stripped debt instruments.  Although the Treasury issued final regulations dealing with original issue discount (“OID”) and premium (such regulations, the “OID Regulations”), the OID Regulations do not address directly the treatment of “Regular Securities” (as defined below).   Furthermore, the REMIC Regulations do not address all of the issues that arise in connection with the formation and operation of a REMIC.  Hence, definitive guidance cannot be provided with respect to many aspects of the tax treatment of Holders.  Moreover, there can be no assurance that the Internal Revenue Service (the “Service”) will not take positions that would be materially adverse to investors.  Finally, the summary does not purport to address the anticipated state income tax consequences to investors of owning and disposing of the Securities.   Consequently, investors should consult their own tax advisors in determining the federal, state, local, foreign, and any other tax consequences to them of the purchase, ownership, and disposition of the Securities. General With respect to each Trust, counsel to the Trust (“Trust Counsel”) will deliver a separate opinion generally to the effect that, assuming timely filing of a REMIC election and compliance with all provisions of the related Trust Agreement and the other issuance and closing documents, the Trust, or one or more segregated pools of Trust Assets (each, an “Asset Pool”), will qualify as one or more REMICs (each, a “Trust REMIC”) for federal income tax purposes.  Trust Counsel also will deliver its opinion that the discussion set forth in this Offering Circular under “Certain Federal Income Tax Consequences,” as amplified or modified by Trust Counsel in the