In light of several non credit-related downgrades of CMBS classes - all involving interest shortfalls - the rating agencies are considering whether to incorporate the risk of a temporary interest shortfall from the risk of non-credit issues, such as litigation, servicer advancing and others.

"There's concern that a small dollar impairment may be reflected in an outsized rating downgrade," said Mary Stuart Freydberg, an analyst at Merrill Lynch.

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