Base Offering Circular - Multifamily 482090 28 not considered unreasonable, however, in the absence of a substantial effect on the present value of a taxpayer’s tax liability. In view of the complexities and current uncertainties as to the manner of inclusion in income of OID on Regular Securities, each investor should consult his own tax advisor to determine the appropriate amount and method of inclusion in income of OID on such Securities for federal income tax purposes. Variable Rate Securities A Regular Security may pay interest at a variable rate (a “Variable Rate Security”).  The rules applicable to variable rate debt instruments, as defined in the OID Regulations (“VRDIs”), apply to a Variable Rate Security only if: (i) such Security is not issued at a premium to its noncontingent principal amount in excess of the lesser of (a) .015 multiplied by the product of such noncontingent principal amount and the WAM (as that term is defined above in the discussion of the de minimis rule) of the Security or (b) 15 percent of such noncontingent principal amount (an “Excess Premium”); (ii) stated interest on the Security compounds or is payable unconditionally at least annually at (a) one or more “qualified floating rates,” (b) a single fixed rate and one or more qualified floating rates, (c) a single “objective rate,” or (d) a single fixed rate and a single objective rate that is a “qualified inverse floating rate”; and (iii) the qualified floating rate or the objective rate in effect during an accrual period is set at a current value of that rate (i.e., the value of the rate on any day occurring during the interval that begins three months prior to the first day on which that value is in effect under the Security and ends one year following that day).  However, if the Variable Rate Security provides for any contingent payments (which do not include qualified stated interest), the Tax Administrator will account for the Variable Rate Security as described in “Certain Federal Income Tax Consequences—Original Issue Discount—Interest Weighted Securities and Non-VRDI Securities” herein. A rate is a qualified floating rate if variations in the rate reasonably can be expected to measure contemporaneous variations in the cost of newly borrowed funds in the currency in which the debt instrument is denominated.  A qualified floating rate may measure contempora- neous variations in borrowing costs for the issuer of the debt instrument or for issuers in general. A multiple of a qualified floating rate is considered a qualified floating rate only if the rate is equal to either (a) the product of a qualified floating rate and a fixed multiple that is greater than .65 but not more than 1.35 or (b) the product of a qualified floating rate and a fixed multiple that is greater than .65 but not more than 1.35, increased or decreased by a fixed rate.  If a Security provides for two or more qualified floating rates that reasonably can be expected to have approximately the same values throughout the term of the Security, the qualified floating rates together will constitute a single qualified floating rate.  Two or more qualified floating rates conclusively will be presumed to have approximately the same values throughout the term of a Security if the values of all such rates on the issue date of the Security are within 25 basis points of each other. A variable rate will be considered a qualified floating rate if it is subject to a restriction or restrictions on the maximum stated interest rate (a “Cap”), a restriction or restrictions on the minimum stated interest rate (a “Floor”), a restriction or restrictions on the amount of increase or