Replies to post #675900 on Mr Cooper Group Inc (COOP)

[lodas]

new flow......again, the PLR that you are referencing specifically states that it is a grantors trust, and the beneficiary is the grantor, which is WMI....there is no reference to a succeeding beneficiary such as the estate of the old WAMU shareholders... if you remember the old shares of WAMU were cancelled for the NOLS, and any succession to the old estate was negated when the shares were cancelled.... there is NO NEXUS from the old company to the new company shares, so hence any estate remains would not go to old shareholders... this chapter 11 was a simple restructuring of the company to form a new company...the old assets of WMI were put in a Grantors Trust, and the beneficiary was WMI... period...the W-9 Form that you allude to is in reference to the signing of the releases for the POR7 in which we were given stock in the new company, and in case the Litigating Trust found more equity assets during the life of the WMIL-T... we know now that Rosen did not pursue legal recourse to litigate any ill gotten assets from the receivership of WAMU....so, my point.......unless there is a specific legal reference to that PLR in naming escrow holders as succeeding WMI as the beneficiary, then, the escrows are out of luck. or the escrow holders would have to mount a court fight over the legal owners of the Grantors Trust assets.... JMO only, but the language in that PLR is specific as to who is the beneficiary to that Trust.... Lodas

[Split T]

newflow, thanks for posting this very relevant information regarding Trust Law and owners. Obviously that is good new to many of us. IMO Coop should flourish this year as new capital becomes openly available and visible for all to see.



HE REASON FOR COLLECTING W-9
IMO.
(b) A trust all of which is treated as owned by one or more grantors or other persons -

(1) In general. In the case of a trust all of which is treated as owned by one or more grantors or other persons, and which is not described in paragraph (b)(6) or (7) of this section, the trustee may, but is not required to, report by one of the methods described in this paragraph (b) rather than by the method described in paragraph (a) of this section. A trustee may not report, however, pursuant to paragraph (b)(2)(i)(A) of this section unless the grantor or other person treated as the owner of the trust provides to the trustee a complete Form W-9 or acceptable substitute Form W-9 signed under penalties of perjury. See section 3406 and the regulations thereunder for the information to include on, and the manner of executing, the Form W-9, depending upon the type of reportable payments made.

https://www.law.cornell.edu/cfr/text/26/1.671-4