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Rewrite Commercial/No New Money: Renewal or Refi?

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Question: 
If we rewrite a commercial loan with no new money, and in the process add an additional borrower, does this fall under the definition of a renewal, refinance, or restructure (under part 365)?
Answer: 

If you are referring to the supervisory loan-to-value limits, I would think it does.

First published on 02/24/2014

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