Just a quick update regarding the status of FAS 140 interpretation. The SEC itself has weighed in and has opened the door for modifications without servicer/seller accounting repercussions. The significance of the SEC statement will be reflected by the number of modifications that are actually undertaken by previously concerned servicers. The door now appears wide open for modifications. We’ll see what actually happens.
Christopher Cox’s July 24 letter to Barney Frank, which summarizes the SEC’s position, can be found here:
