CRT-Eligible Profile Summary
CAS: Summary of Key Tax, Legal and
Regulatory Considerations
Issuer
Topic
CAS Direct Debt
Fannie Mae
Registration
Exempt under Fannie Mae Charter Act.
CAS REMIC
CAS REMIC Trust, a wholly-owned, non-consolidated subsidiary of
Fannie Mae. Fannie Mae is sponsor and depositor.
Exempt under Rule 144A.
Offering Restrictions
Regulation S
Sales to REITS
Tax Treatment
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.
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 A REMIC security will be a qualified REIT asset and will produce
the REIT tax tests, so are qualifying assets for REITs, but qualified income for REITs.
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.
All tranches are treated as debt for tax.
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