Base Offering Circular - Multifamily 482090 26 into account by the parties in pricing the Regular Security typically will be subsumed in the Pricing Prepayment Assumptions and thus will be reflected in the Security’s yield to maturity. If a subsequent Holder’s adjusted basis in the Security immediately after the acquisition exceeds the adjusted issue price of the Security, but is less than or equal to the sum of the Deemed Principal Payments to be received under the Security after the acquisition date, the amount of OID on the Security will be reduced by a fraction, the numerator of which is the excess of the Security’s adjusted basis immediately after its acquisition over the adjusted issue price of the Security and the denominator of which is the excess of the sum of all Deemed Principal Payments to be received on the Security after the acquisition date over the adjusted issue price of the Security.  For that purpose, the adjusted basis of a Regular Security generally is reduced by the amount of any qualified stated interest that is accrued but unpaid as of the acquisition date.  Alternatively, the subsequent Holder of a Regular Security having OID may make a Constant Yield Election with respect to the Security, as described below.  If the subsequent Holder’s adjusted basis in a Regular Security, immediately after its acquisition, exceeds the sum of all Deemed Principal Payments to be received on the Security after the acquisition date, the Holder will no longer be required to accrue OID on the Security, and the Holder can elect to reduce the amount of interest income recognized on the Security by the amount of amortizable premium.  See “—Amortizable Premium” below. Special Rules and Considerations.  If the amount of OID computed for a Regular Security during an accrual period is negative (“Negative OID”), the amount of OID on such Security will be treated as zero for that period, and the Holder generally will be entitled to offset the Negative OID only against future positive OID on the Security.  Although the law is unclear in some respects, a corporate Holder whose Regular Security has Negative OID may be entitled to deduct a loss when and to the extent that its adjusted basis in the Regular Security exceeds the maximum amount of future payments to which the Regular Security entitles it.  Similarly, certain non- corporate Holders may be entitled to the same treatment if their Regular Securities are involved in their trade or business.  It is unclear whether other non-corporate Holders may claim any tax benefit related to a Regular Security with Negative OID (other than an offset against future positive OID generated by such Security) prior to its maturity.  Prospective Holders should consult their own tax advisors with respect to the tax consequences to them of Negative OID. The OID Regulations contain an aggregation rule (the “Aggregation Rule”) under which two or more debt instruments issued in connection with the same transaction (or related transactions in certain circumstances) generally are treated as a single debt instrument for federal income tax accounting purposes if issued by a single issuer to a single Holder.  The Aggregation Rule, however, does not apply if the debt instrument is part of an issue (i) a substantial portion of which is traded on an established market or (ii) a substantial portion of which is issued for cash (or property traded on an established market) to parties who are not related to the issuer or Holder and who do not purchase other debt instruments of the same issuer in connection with the same transaction or related transactions.  In most cases, the Aggregation Rule will not apply to Regular Securities of different Classes that are sold to the public because one or both of the exceptions to the Aggregation Rule will have been met.  Although the Tax Administrator will apply the Aggregation Rule to all regular interests in a Trust REMIC that are held by a related