Pandemic Modification and Flood MIRE Event

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• March 31, 2020 at 1:04 pm EDT #31929
  rcooper

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  Question from our recent webinar, Pandemic Relief – Managing Compliance Issues:
  Are modifications where the maturity date is not extended and no new note is signed are MIRE events?

  March 31, 2020 at 1:04 pm EDT #31930
  rcooper

  Member

  MIRE events trigger the flood rules; MIRE is an acronym for make, increase, renew or extend. If you accomplish the accommodation using a new note, you are MAKING a new loan. If you extend the maturity date you are EXTENDING the loan. If you increase the loan balance you are INCREASING the loan. If you modify a loan without extending the loan term, without using a new note (which would be considered making a loan), without increasing the balance, and the loan isn’t being renewed, then it seems you have modified the loan in a way that would not trigger the flood requirements.

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