The Liquidating Trust Agreement provides that the Liquidating Trust was “established for the purpose of liquidating and distributing the Liquidating Trust Assets in accordance with Treasury Regulations Section 301.7701-4(d), with no objective to continue or engage in the conduct of a trade or business, except to the extent reasonably necessary to, and consistent with, its liquidating purpose….” The Trust Agreement further provides that “no part of the Liquidating Trust Assets shall be …used or disposed of in furtherance of any trade or business.” Consistent with these provisions, and in light of the nature of the Liquidating Trust’s assets, the Liquidating Trust does not believe that to date it has recognized any income that would constitute trade or business income (or unrelated business taxable income or income that is effectively connected to the conduct of a trade or business in the United States, though such characterizations may depend in part on each Unitholder’s unique tax position) , and it does not anticipate that it will do so in the future.

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David was formerly the Executive Managing Director of Goldin Associates, a leading US restructuring advisory firm. He was promoted to chief operating officer in 2007. Molinaro was a member of the Bear Stearns’ Management and Compensation Committee from 1998 through 2008. from the Syracuse University College of Law where he is a member of the Board of Advisors and its Executive Committee. The Trust maintains a website at where Unitholders may obtain information concerning the Trust. The Trust continues to pursue strategies to maximize the recoveries of the Mortgage Asset portfolio for the benefit of the Unitholders.

He was CRO of Refco, a diversified financial services company that was one of the largest-ever US bankruptcies, and has acted as CRO, CEO, turnaround manager or financial advisor for companies in diverse industries, including apparel and textile, energy and natural resources, financial services, food and consumer products, information technology, manufacturing, media and telecommunications, professional services, real estate, retail and wholesale distribution. David is a director of Terra Form Power and reorganized Lehman Brothers. is a Group Managing Director and heads the UBS Non-Core and Legacy division. He was promoted to chief financial officer in 1996 and held that title through 2008. Molinaro has also served as a director of the Securities Industry and Financial Markets Association (SIFMA). Sonkin has lectured and served on panels covering topics such as distressed debt trading, utility restructurings and life insurance company reorganizations. Sonkin is a cum laude graduate of the Temple University College of Liberal Arts where he earned a bachelor’s degree in political science and currently serves as a member of the Board of Visitors. Res Cap Liquidating Trust’s mission is to maximize returns to Unitholders by vigorously pursuing and resolving the mortgage correspondent litigation and monetizing the Trust’s remaining assets in a timely and efficient manner. Section 2.5(b) of the Liquidating Trust Agreement provides that if assets cannot be transferred to the Liquidating Trust by a Debtor entity, or it is impracticable or inadvisable to do so, the Debtor entity will continue to retain those assets until it is notified that the Liquidating Trust may receive the assets.

A basis difference as described above could affect the Beneficiary’s taxable income and loss from holding Trust Units, because the basis difference in Units generally will also result in the Beneficiary having a tax basis in its share of the underlying Trust assets that differs from the basis that the Trust uses in computing its taxable income and loss.

A Beneficiary with a basis difference should consult its tax advisor as to whether and how any adjustments should be made as a result of such differing basis to the per Unit Trust items of taxable income and loss as reported by the Trust for the periods that such Beneficiary holds its Units.

Cap Re, which is taxed as a C corporation, was owned by GMAC Mortgage, LLC and is now owned by the Liquidating Trust.

Cap Re provided reinsurance on mortgage loans originated by GMAC Mortgage LLC and its affiliates and correspondent lenders through entering into reinsurance agreements with various primary mortgage insurers in which the company assumed the risk of loss in excess of various loss percentages.

Previously, he was a Managing Director and Co-Head of Special Situations Trading at HSBC Securities, where he headed up credit research. Doheny was a portfolio manager at Fintech Advisory Inc., a hedge fund focusing on undervalued securities and turnarounds in the U. He received a BA from Allegheny College and a Juris Doctor from Cornell Law School. The Res Cap Liquidating Trust was established in December 2013 under the Second Amended Joint Chapter 11 Plan of Residential Capital, LLC, et al.

David Pauker is a turnaround manager and restructuring advisor with more than 25 years of experience advising underperforming companies and their investors. to liquidate and distribute assets of the debtors in the Res Cap bankruptcy case. Ray has extensive experience as a chief restructuring officer and plan administrator in notable bankruptcy cases and situations involving Overseas Shipholding Group Inc., Nortel Networks Inc. The Trust’s mortgage assets include mortgage loans, servicer advances, interest income, real estate owned, trading securities, net of costs to sell the assets.

Effective as of January 15, 2014, the Liquidating Trust contributed those properties (as well as certain interests in mineral rights that have only nominal value) to Res Cap Securities Holdings Co., a wholly-owned U. It is contemplated that the corporate subsidiary is a United States real property holding corporation within the meaning of section 897 of the U. As of September 30, 2017, Res Cap Securities Holdings Co owed approximately 35 properties in 23 states.

The Trust is a liquidating trust for federal and, if applicable, state income tax purposes.

The Liquidating Trust, through its agents, shall wind down the affairs of and dissolve the Debtors and their subsidiaries including the Non-Debtor subsidiaries.