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ARTICLE · 24 APRIL 2020

Covid-19 Update: Coronavirus-Related Remic Considerations

Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
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Update: On April 13, the IRS issued a revenue procedure that addresses a number of the concerns discussed in this memo. For more on the revenue procedure, click here.

United StatesFinance and Banking
Gary Silverstein
Gary Silverstein
Linda Swartz
Linda Swartz
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Update: On April 13, the IRS issued a revenue procedure that addresses a number of the concerns discussed in this memo. For more on the revenue procedure, click here.

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 common vehicles for securitizing mortgage loans.  With careful planning, REMICs can continue to be highly useful during these difficult times.  This alert explores the feasibility of continuing to use REMICs to securitize mortgage loans subject to forbearance and potential default as a result of the pandemic.1 

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