Base Offering Circular - Multifamily 482090 24 Amount of Original Issue Discount.  The amount of OID on a Regular Security equals the excess, if any, of the Security’s “stated redemption price at maturity” over its “issue price.” Under the OID Regulations, a debt instrument’s stated redemption price at maturity is the sum of all payments provided by the instrument other than “qualified stated interest” (“Deemed Principal Payments”).  Qualified stated interest, in general, is stated interest that is unconditionally payable in cash or property (other than debt instruments of the issuer) at least annually at (i) a single fixed rate or (ii) a variable rate that meets certain requirements set out in the OID Regulations.  See “— Variable Rate Securities” below.  Thus, in the case of any Regular Security, the stated redemption price at maturity will include all Deemed Principal Payments payable on that Security.  Because an Accrual Security generally does not require unconditional payments of interest at least annually, all payments due thereon, whether designated as principal, accrued interest, or current interest will constitute Deemed Principal Payments.  Consequently, all Accrual Securities will be considered to be issued with OID for federal income tax purposes. The issue price of a Regular Security generally will equal the initial price at which a substantial amount of Securities of the same Class is sold to the public (including any amounts paid for interest accrued as of the Closing Date under the terms of the Security). Under a de minimis rule, a Regular Security will be considered to have no OID if the amount of OID is less than 0.25% of the Security’s stated redemption price at maturity multiplied by its weighted average maturity (“WAM”).  For that purpose, the WAM of a Regular Security is the sum of the amounts obtained by multiplying the amount of each Deemed Principal Payment by a fraction, the numerator of which is the number of complete years from the Security’s issue date until the payment is made, and the denominator of which is the Security’s stated redemption price at maturity.  Although no guidance has been issued regarding the application of the de minimis rule to REMIC regular interests, it is expected that the WAM of a Regular Security will be computed using the Pricing Prepayment Assumptions.  A Regular Holder will include de minimis OID in income on a pro rata basis as stated principal payments on the Security are received or, if earlier, upon disposition of the Security, unless the Holder makes the “Constant Yield Election” (as defined below). Regular Securities may bear interest under terms that provide for a teaser rate period, interest holiday, or other period (a “Teaser Period”) during which the rate of interest payable on the Securities is lower than the rate payable during the remainder of the life of the Securities (“Teaser Securities”).  The OID Regulations provide an alternative test under which a Teaser Security may be considered to have a de minimis amount of OID (the “Alternative De Minimis Amount”) even though the amount of OID on such Security would be more than de minimis as determined under the regular test.  The Alternative De Minimis Amount applies only if the stated interest on a Teaser Security would be qualified stated interest but for the fact that the interest rate effective in the Teaser Period or Periods is below the rate applicable for the remainder of its term.  Under the alternative test, the amount of OID on a Teaser Security that is measured against the Alternative De Minimis Amount is the greater of (i) the excess of the stated principal amount of the Security over its issue price (“True Discount”) and (ii) the amount of interest that would be necessary to be payable on the Security in order for all stated interest to be qualified stated interest (the “Additional Interest Amount”).  If the amount of OID on a Teaser Security eligible for the alternative test exceeds the Alternative De Minimis Amount, the Security will be treated