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SECURITIES AND EXCHANGE COMMISSION
FORM 8-K
CURRENT REPORT
Pursuant to Section 13 or 15(d) of the
Securities Exchange Act of 1934
July 16, 2003
Date of Report (Date of Earliest Event Reported)
SEQUOIA MORTGAGE FUNDING CORPORATION
Delaware | 333-103634 | 91-1771827 | ||
(State or Other Jurisdiction of Incorporation) | (Commission File Number) | (I.R.S. Employer Identification No.) |
591 Redwood Highway, Suite 3120
Mill Valley, CA 94941
(415) 389-7373
SEQUOIA RESIDENTIAL FUNDING, INC.
(Exact Name of Co-Registrant as Specified in Its Charter)
Delaware | 333-103634 | 35-2170972 | ||
(State or Other Jurisdiction of Incorporation) | (Commission File Number) | (I.R.S. Employer Identification No.) |
591 Redwood Highway, Suite 3160
Mill Valley, CA 94941
(415) 389-7373
Not Applicable
Item 5. Other Events | ||||||||
Item 7(c). Exhibits | ||||||||
SIGNATURE | ||||||||
EXHIBIT INDEX | ||||||||
Exhibit 8.1 |
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INFORMATION TO BE INCLUDED IN THE REPORT
Item 5. Other Events
On March 6, 2003, Sequoia Mortgage Funding Corporation and Sequoia Residential Funding, Inc. (together, the “Co-Registrants”) filed a Shelf Registration Statement on Form S-3 (Registration Statement No. 333-103634) (the “Registration Statement”), including a prospectus (the “Prospectus”) with the Securities and Exchange Commission (“SEC”) under the Securities Act of 1933, covering asset-backed securities (issuable in series). The Registration Statement was declared effective on March 21, 2003. At the time the Registration Statement was filed with the SEC, an opinion of tax counsel GnazzoThill, A Professional Corporation (“GnazzoThill”), as to federal income tax matters in connection with the securities being registered by the Co-Registrants was filed with the Registration Statement.
Effective June 1, 2003, the attorneys of GnazzoThill combined with the law firm of Chapman and Cutler, now known as Chapman and Cutler LLP.
The Opinion of Chapman and Cutler LLP as to federal income tax matters in connection with the Registration Statement is attached hereto as Exhibit 8.1.
Item 7(c). Exhibits
8.1 | Opinion of Chapman and Cutler LLP, dated July 16, 2003, with respect to federal income tax matters. |
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SIGNATURE
Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned thereunto duly authorized.
Date: July 16, 2003 | ||||
SEQUOIA MORTGAGE FUNDING CORPORATION | ||||
By: | /s/ Harold F. Zagunis | |||
Harold F. Zagunis | ||||
Secretary | ||||
SEQUOIA RESIDENTIAL FUNDING, INC. | ||||
By: | /s/ Harold F. Zagunis | |||
Harold F. Zagunis | ||||
Secretary |
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EXHIBIT INDEX
Exhibit | ||
Number | ||
8.1 | Opinion of Chapman and Cutler LLP, dated July 16, 2003, with respect to federal income tax matters. |