When House Speaker Paul Ryan announced earlier this month that the House would vote on S.2155, I wasn’t holding my breath (you know you’re on your last lame duck leg when a “senior GOP lawmaker” says you’ve “run out of juice”).
Miracles do happen AND sometimes I love to be wrong (but – shh…don’t tell my husband): In the spirit of deal making, the House just passed S. 2155 (the Economic Growth, Regulatory Relief, and Consumer Protection Act) with bipartisan support (Yup – the Dems and the Republicans did this in both the House and the Senate…maybe there is more to come!). The President still needs to sign the bill before it becomes law, which everyone expects will happen soon.
While it’s great news that S.2155 passed, it’s not law until Mr. President signs it and even after that, before YOU (yes – you – regulated banks) start de-classifying loans and moving money, let’s take a step back. It probably makes sense to have some discussion with your examiners and the regulators to figure out what the best approach is regarding legacy loans (after all – we are in a bit of uncharted territory with legislation of capital requirements and the regulators do have the last say, I think). And – let us not forget about HVADC-which we have not (yet) killed and buried. Stay tuned for more from us on this topic and much more. For now, I am going to pop the champagne and take a BIG sip!
P.S. For those of you who don’t care about HVCRE, S.2155 has some other gems in it. More on that later!
