[pcorder]

If a bank increases the principal balance of a loan due to attorney fees or delinquent taxes (paid by the bank) that are charged back to the loan, does that trigger a MIRE event (due to the principal balance being increased)?

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[rcooper]

Pcorder,
I apologize we overlooked your question until now. We view this similarly to adding a force-placed premium to the loan balance. In that regards, we have heard that some regulators/agencies view it as a MIRE event while others do not. We believe the safest course of action, until we have definitive guidance, is to consider increasing the principal balance due to the addition of insurance premiums, or other fees as you mentioned, as a MIRE event.

[Author]

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