CREFC Adopts Proposed Disclosure Templates - IRP Version 5.2
December 21, 2012:
In response to investor concerns and requests for more information surrounding special servicer activities, CREFC created a Transparency Working Group last summer.
Process: The CREFC Transparency Working Group was comprised of the four largest special servicers (LNR, C-III, CWCapital and Midland), leadership of the CREFC IG Bondholders Sub-Forum (Wells Fargo, AIG and NYLIM), a trustee (Wells Fargo), and Issuer’s counsel (Cadwalader).
The Working Group finalized recommendations for a revised modification report and new liquidations reports that will capture information on fees, affiliates, and actions taken on loan modifications, as well as final resolutions for legacy loans. These proposed disclosure templates were approved by the CREFC Investor Reporting Package Committee and the CREFC Forums and have now been adopted by CREFC as Investor Reporting Package (IRP™) Version 5.2.
Linked below are examples of the recommended disclosure templates: a revised Loan Modification Report; a new REO Liquidation Report; and a new Loan Liquidation Report. Like the current CREFC Loan Modification Report, these templates will flow through the IRP and be posted to the Trustee websites.
CREFC will leave it up to each special servicing shop to develop a form that is most efficient and effective for them to produce, including the level of detail surrounding proposed data fields. The examples below are provided to illustrate the “concept” of the disclosure templates and to show the pertinent data fields, as well as the type of disclosure that investors are seeking.
Additionally, the CREFC IRP Committee has created narrative language to provide logistical clarification for special servicers on how the templates should work.
Implementation Timing: The Effective Date is February 1, 2013.
Loan and REO Liquidation Report Guidance