On July 8, the Internal Revenue Service published Revenue Procedure 2008-4 which states that the IRS will not challenge the tax status of Real Estate Mortgage Investment Conduits that modify certain subprime adjustable rate loans in accordance with the provisions of the newly issued framework for fast-track loan modifications published by the American Securitization Forum on the same date.

http://www.americansecuritization.com/uploadedFiles/RevProc200847.pdf