MEPT is open for investment by pension funds that are exempt from Federal income taxes under Section 501(a) of the Internal Revenue Code of 1986 ("the Code"), by reason of qualifying under Section 401(a) of the Code, but only to the extent the requirements of section 584 of the Internal Revenue Code and applicable regulations of the Comptroller of the Currency are satisfied. The vast majority of investors in MEPT are multi-employer pension plans and public employee pension plans.