*Letters

Loan Modification Proposal

Published on:
July 25, 2008
Committee:

SIFMA provides comments to the Internal Revenue Service (IRS) on describing when mortgage loans in Real Estate Mortgage Investment Conduits (REMICs) or grantor trusts may be modified prior to default, without the IRS challenging their tax status, Section 9 of Internal Revenue Procedure 2008-28.  SIFMA shares its concerns with definitions of the term “owner-occupied” as well as consistencies with the Securities and Exchange Commission’s (SEC’s) Regulation AB regarding mortgage-backed securities.

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