OVERVIEW OF FINAL REGULATIONS
         TD 8610 -- TAXABLE MORTGAGE POOLS (FI -55- 91)

     A taxable mortgage pool -- an entity that owns real estate mortgages financed by
debt with more than one maturity and links debt payments to mortgage payments -- is
required to pay tax as a corporation unless it elects to be classified as a real estate
mortgage investment conduit -- or REMIC.
     If a taxable mortgage pool receives annual interest payments exceeding the interest
it pays, the resulting income is taxed.  REMIC rules provide a different way of taxing
this income.
     These regulations help define whether an entity is a taxable mortgage pool.  Among
other things, they explain that pools of certain troubled loans and pools created to
liquidate real estate mortgages within a three-year period are not taxable mortgage
pools.  A government organization is not considered a taxable mortgage pool if it uses
mortgages to issue debt to perform a governmental purpose. 
     The final regulations became effective 30 days after their publication on page
40086 of the Federal Register of August 7, 1995.