SECTION 10. DRAFTING

INFORMATION

The principal author of this revenue procedure is Diana Imholtz of the Office of Associate Chief Counsel (Financial Institutions and Products). For further information, contact Ms. Imholtz at (202) 622–3930 (not a toll-free call).

REMIC on the grounds that the transactions are not among the exceptions listed in § 1.860G–2(b)(3);

.02 The Service will not contend that the transactions are prohibited transactions under section 860F(a)(2) on the grounds that the transactions resulted in one or more dispositions of qualified mortgages and that the dispositions are not among the exceptions listed in section 860F(a)(2)(A)(i)–(iv); .03 The Service will not challenge a securitization vehicle’s classification as a trust under § 301.7701–4(c) on the grounds that the transactions manifest a power to vary the investment of the certificate holders; and

.04 The Service will not challenge a securitization vehicle’s qualification as a

REMIC on the grounds that the transactions resulted in a deemed reissuance of the REMIC regular interests.