If these are being refinanced internally with no cash out it seems to me that you would be able to use the following exclusion to not have to carry them as in excess of the supervisory LTV limits:
Excluded Transactions
The agencies also recognize that there are a number of lending situations in which other factors significantly outweigh the need to apply the supervisory loan-to-value limits. These include:
Loans that are renewed, refinanced, or restructured without the advancement of new funds or an increase in the line of credit (except for reasonable closing costs), or loans that are renewed, refinanced, or restructured in connection with a workout situation, either with or without the advancement of new funds, where consistent with safe and sound banking practices and part of a clearly defined and well-documented program to achieve orderly liquidation of the debt, reduce risk of loss, or maximize recovery on the loan.
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Not a legal opinion, just my personal opinion.
"A nickel isn't worth a dime today."- Yogi Berra