FASB’s Invitation to Comment – Agenda Consultation
SIFMA provided comments to the Financial Accounting Standards Board (FASB) on its Invitation to Comment - Agenda Consultation (the “ITC”).
Summary
SIFMA provides comments to the Internal Revenue Service (IRS) on 9 of Revenue Procedure 2008-28 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. SIFMA is concerned 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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