The Federal Reserve, OCC and FDIC have (finally) issued the Final HVCRE Rule (for background, our analysis of the 2018 Notice of Proposed Rulemaking and 2019 Notice of Proposed Rulemaking are here and here), regarding High...more
2/3/2020
/ Bank Holding Company ,
Banking Sector ,
Commercial Real Estate Market ,
EGRRCPA ,
FDIC ,
Federal Reserve ,
Final Rules ,
Financial Regulatory Reform ,
HVCRE ,
HVCRE Loans ,
HVCRE Rule ,
Land Developers ,
OCC ,
Real Estate Development
Just when you thought the regulators had forgotten about HVCRE ADC, they issued a new notice of proposed rulemaking like they were Beyoncé surprise-dropping a new album. And then…they disappeared again! We were waiting for...more
10/23/2019
/ Banks ,
Construction Loans ,
FDIC ,
Federal Bank Regulatory Agencies ,
Federal Reserve ,
Financial Institutions ,
HVCRE ,
HVCRE Loans ,
Land Developers ,
Notice of Proposed Rulemaking (NOPR) ,
Proposed Rules ,
Residential Real Estate Market
On September 18, 2018, the Federal Reserve, FDIC and OCC released a Notice of Proposed Rulemaking (NPR) regarding HVCRE. The good news is that the stated intent is not to alter any of the improvements made by EGRRCPA, instead...more
Since my last post, the Economic Growth, Regulatory Relief, and Consumer Protection Act (which some are referring to as EGRRCPA – oof.) was signed into law by President Trump on May 24th. Section 214, titled, “Promoting...more
At long last (at least for those of us who have been checking the Federal Register daily), the proposed HVADC rule has been published in the Federal Register and is open for comment...more
On September 27, 2017, the Federal Reserve, FDIC and OCC released a Notice of Proposed Rulemaking (NPR) that they describe as simplifying compliance with certain aspects of the agencies’ risk based capital (RBC) rules to,...more