Connecticut Avenue Securities Investor Presentation
Summary of Key Tax, Legal and
Regulatory Considerations
Issuer
Topic
CAS direct debt
Fannie Mae
Registration
Offering Restrictions
Regulation S
Sales to REITS
Tax treatment
Exempt under Fannie Mae Charter Act
Within the U.S.: Notes offered only to "Qualified
Institutional Buyers" as defined in Rule 144A under
the Securities Act.
Outside the U.S.: Notes offered only to non-U.S.
persons pursuant to Regulation S of the Securities
Act.
CAS are deemed to be government securities for
purposes of the REIT tax tests, so are qualifying
assets for REITs, but generally are less attractive
because they do not produce qualifying real
property income for REITs.
M1 and M2 are debt for tax
B1 is a contingent notional principal contract for tax
CAS REMIC
CAS REMIC Trust, a wholly-owned, non-consolidated
subsidiary of Fannie Mae.
Fannie Mae is sponsor and depositor
Exempt under 144A
Within the U.S.: Notes offered only to "Qualified
Institutional Buyers" as defined in Rule 144A under the
Securities Act.
Outside the U.S.: Notes offered only to non-U.S. persons
pursuant to Regulation S of the Securities Act.
A REMIC security will be a qualified REIT asset and will
produce qualified income for REITS.
All tranches are treated as debt for tax
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