Base Offering Circular – Multifamily 27 Single Class REMICs In the case of certain Trust REMICs that are considered to be “single-class REMICs” under temporary Treasury regulations, Holders of Regular Securities who are individuals, trusts, estates, or pass-through entities in which such persons hold interests may be required to recognize certain amounts of income in addition to interest and discount income.  A single-class REMIC, in general, is a REMIC that (i) would be classified as an investment trust in the absence of a REMIC election or (ii) is substantially similar to an investment trust and was structured with the principal purpose of avoiding the allocation of “allocable investment expenses” (i.e., expenses normally allowable under section 212 of the Code, which may include servicing and administrative fees and the guarantee fee with respect to the Trust Assets) to Holders of Regular Securities.  Under the temporary Treasury regulations, each Holder of a regular or residual interest in a single-class REMIC is allocated (i) a share of the REMIC’s allocable investment expenses and (ii) a corresponding amount of additional income.  Section 67 of the Code permits an individual, trust or estate to deduct miscellaneous itemized expenses (including section 212 expenses) only to the extent that such expenses, in the aggregate, exceed 2% of its adjusted gross income.  Consequently, an individual, trust or estate that holds a regular interest in a single-class REMIC (either directly or through a pass-through entity) will recognize additional income with respect to such regular interest to the extent that its share of allocable investment expenses, when combined with its other miscellaneous itemized deductions for the taxable year, is less than 2% of its adjusted gross income.  Any such additional income will be treated as interest income.  In addition, Code section 68 currently provides that the amount of itemized deductions otherwise allowable for the taxable year for an individual whose adjusted gross income exceeds a certain amount will be reduced.  The amount of such additional taxable income recognized by Holders who are subject to the limitations of either section 67 or section 68 may be substantial and may reduce the after-tax yield to such Holders of an investment in the Securities of an affected Trust.   Where appropriate, the Offering Circular Supplement for a particular Trust will indicate that the Holders of related Securities may be required to recognize additional income as a result of the application of the limitations of either section 67 or section 68 of the Code.  Non-corporate Holders of Regular Securities evidencing an interest in a single-class REMIC also should be aware that miscellaneous itemized deductions, including allocable investment expenses attributable to such REMIC, are not deductible for purposes of the alternative minimum tax (“AMT”). Original Issue Discount Overview.  Certain Classes of Regular Securities may be issued with OID within the meaning of section 1273(a) of the Code.  In general, such OID will equal the difference between the “stated redemption price at maturity” of the Regular Security and its issue price.  Holders of Regular Securities as to which there is OID should be aware that they generally must include OID in income for federal income tax purposes on an annual basis under a constant yield accrual method that reflects compounding.  In general, OID is treated as ordinary interest income and must be included in income in advance of the receipt of the cash to which it relates. The amount of OID required to be included in a Regular Holder’s income in any taxable year will be computed in accordance with section 1272(a)(6) of the Code, which provides for the accrual of OID under a constant yield method on regular interests in a REMIC.  Under