When the brand new servicer safe harbor laws or some brand of it is enacted toward rules, its unsure just how useful it might be to require acting servicers to seek to remove restrictions for the financing adjustment in the agreements
Given that added bonus payments in order to servicers and you may financial owners beneath the Modification Program are not considered because of the REMIC laws and regulations, it will be ideal for brand new Treasury Department so you’re able to describe one including added bonus money won’t bring about unfavorable tax outcomes underneath the REMIC laws and regulations.
Similar to the potential taxation problems with incentive money discussed more than, the latest common payment to be produced by the newest Treasury Service significantly less than brand new Amendment System and brings up uncertainty over if an excellent securitization searching eg percentage would have bad tax outcomes underneath the REMIC regulations. Therefore, it will be great for the new Treasury Company so you can explain you to definitely including common costs made by the newest Treasury Agency would not end in unfavorable income tax effects under the REMIC statutes.
Added bonus costs so you’re able to servicers and home loan proprietors raise potential tax points for mortgage loans included in securitizations one to opted REMIC status
- Selection Whenever Improvement Aren’t effective.