"MIRE" - Gotta love our commercial lenders. We have commercial lines of credit without maturity dates, callable on demand. BUT, every year they go through a required review process at which time they are "renewed", according to the commercial folks.
I believe this is simply an internal process, which allows us to call the loan if there are valid reasons. Is there anyway this could be considered a "renewal" under the flood triggers and require a new SFHDF?

Not in my mind. Renewal is based on the contractual obligation - not an internal review to determine if they want the line to continue.

Those are my thoughts too. But conducted training today and when I discussed MIRE, the question came up. Thanks