Mr Cooper Group Inc (COOP)

[newflow]

WHAT WOULD THEY DO WITH "DCR NOLS"?
Treasury Regulation 1.468B-9(c)(6) provides that upon the termination of a Disputed Ownership
Fund, the claimants to the fund’s net assets succeed to the funds unused net operating loss carryforwards.
This regulation also provides that “if the fund's net assets are distributable to more than one claimant, the
unused net operating loss carryover. . . must be allocated among the claimants in proportion to the value
of the assets distributable to each claimant from the fund.”
Pursuant to the Plan, the DCR was created and elected to be treated as a “Disputed Ownership
Fund” pursuant to Treasury Regulation 1.468B-9(c)(2). On the basis of the foregoing, a beneficiary’s
share of the unused net operating loss of the DCR is set forth in the Beneficiary Tax Reporting Letter
distributed by the Trust for the year ended December 31, 2020
. This amount was calculated by allocating
the unused net operating loss of the DCR among the final claimants based on each claimant’s portion of
the final cash distribution that was initiated in January 2020.