IRP 6 Needs Support! – Send an email to

As MISMO’s liaison to the CMSA to support the adoption of IRP 6 as the new reporting standard for CMBS, I have an inside perspective on the prospects of this standard being adopted. The official comment period for IRP 6 ended on February 20 and the CMSA only received a handful of comments (around 5) with most being against adoption.

From what I understand, I had the only supportive comments, and the other comments were from a handful of master servicers and trustees who were very negative on adoption of IRP 6, presumably for reasons discussed elsewhere on this blog. With the majority of comments being negative, the CMSA is trying to build a case for adoption. I worry that if the positive voices are not registered, the special interests may stifle the transparency promised by IRP 6.

We need Your Help!
If you are a member of the CMSA or have an interest in CMBS bonds (especially if you are a current or prospective investor), please send an email to and put you and your firm on record as being supporters of IRP 6 for open and transparent CMBS standards. State in the email who you are, what role you play in CMBS, and that you support IRP 6.

After hearing the news that most comments were negative and being told that CMSA will be hard pressed to push the standard through without industry support, I sent the following email to the CMSA.

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Dear CMSA IRP Committee,

I am a member of the Board of Governors of MISMO, and one of our key agenda items for 2009 is to help the CMSA usher in IRP version 6 in XML. I have been appointed as the MISMO liaison to support the CMSA IRP committee and want to offer any help needed to bring about the acceptance of this important standard.

I know there is some resistance from a handful of master servicers and trustees in implementing IRP 6. However, the investor community and the rating agencies are demanding cleaner, more complete data to better evaluate the value of CMBS bonds. Unfortunately, most players in the investor community do not understand the importance of XML to meet their information demands (they just want the data available and useable and complain loudly when it is not there). I believe if the investor community knew the relationship between solving their issues and IRP 6, they would be loud and vocal supporters of IRP 6. Unfortunately, they do not really understand the mechanics of moving data and therefore were largely silent in making comments on the exposure draft. Instead, all you received were mostly negative comments from a few servicers and trustees.

We at MISMO, and I know the two of you, understand the conversion of the IRP to XML is required if we are going to meet the information demands of the investors. Without investors, we do not have a viable asset class. Therefore, the requirements of this critical constituency and the overall goal of transparency should trump all objections. Do not let a few negative, self serving comments from a handful of servicers / trustees alter your dedication to the noble goal of data transparency.

I will reach out to all of you over the next few days to figure out a strategy to keep momentum going on this critical improvement in transparency and reporting. First and foremost is educating the investors on why this is important to help the CMSA build a case to push ahead with IRP 6. In the meantime, check out this timely article about XML and financial reporting to help remind us of the importance and righteousness of our mission.



Jim Flaherty
(415) 576 -8008

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Jim Flaherty is CEO of and the creator of the Backshop loan origination system. He is a trained credit professional with experience installing enterprise underwriting systems for commercial real estate lenders, rating agencies and investors.

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