As regular readers of CrunchedCredit will know, I recently pitched the idea of amending our hoary old REMIC statute to allow additions of collateral after the startup date window to allow modification to performing loans (and...more
This title may be a bit ambitious, a triumphalist embrace of hope over experience? But it’s time for the effort to be made....more
On October 21 and 22, 2014, pursuant to the requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the “Dodd-Frank Act”), the Securities and Exchange Commission (the “SEC”) and various federal...more
Under the REMIC rules, a mortgage loan ceases to be a good REMIC asset if the borrower replaces the real property collateral with government securities (known as defeasance) less than two years after the REMIC’s startup date....more
The Internal Revenue Service (IRS) issued Revenue Procedure 2021-12 on January 14, extending the safe harbors in Revenue Procedures 2020-26 and 2020-34 to September 30, 2021. This LawFlash discusses the portion of Revenue...more
The Internal Revenue Service (IRS) issued Revenue Procedure 2020-26 on April 13, 2020, providing relief to certain securitization vehicles, including investment trusts and real estate mortgage investment conduits (REMICs),...more
The Internal Revenue Service on Monday, April 13 issued welcome relief to the securitization industry, providing that certain forbearances and related modifications to mortgages will generally not cause real estate mortgage...more
I. Introduction - The COVID-19 pandemic has created significant headwinds for mortgage loans. Loan forbearances and workouts raise tax complexities for real estate mortgage investment conduits (REMICs), which are the most...more
Effective December 24, 2015, all securitizations of residential mortgage loans (RMBS), both public and private, will be subject to the Credit Risk Retention Rule (the “Rule”).[1] The Rule was promulgated on December 24, 2014,...more