HVCRE: The Continuing Saga of Lenders
On Tuesday, September 10, the Federal Reserve announced a reproposal of the much discussed and awaited Basel III Endgame. However, before we dive into the reproposal, it is important to take a step back and look at how we got...more
On July 9 and 10, the Fed Chair Jerome Powell testified at the respective financial committees under the U.S. Senate and U.S. House of Representatives. Lawmakers asked questions on various Fed initiatives, such as the...more
On September 18, 2023, the U.S. Basel III Endgame proposal was published in the Federal Register. The comment period ended on January 16, 2024, with the banking regulators (the Federal Reserve, the OCC, and the FDIC) having...more
On June 17, in a letter to Fed Chair, Jerome Powell, Senator Elizabeth Warren (D-MA) requested information regarding discussions of potentially cutting the Basel III capital requirements in half. Warren highlighted reports...more
I. IMPLEMENTING BASEL III THROUGH THE CRR III REGULATION - The Basel III standards comprise a package of reforms that were largely agreed by the Basel Committee on Banking Supervision ("BCBS") in December 2017 and set out...more
More than 1,800 industry players attended the 13th annual Global Fund Finance Symposium that wrapped up yesterday afternoon at the Fontainebleau in Miami Beach. There was a lot to talk about in terms of market evolution...more
Welcome to the latest edition of the Spectrum, covering hot-topic issues in the structured finance markets in the U.S. and UK. This edition features the shifting single-family rental landscape, what’s next for EDGAR, and...more
With new banking rules on the horizon for financial institutions, lenders are looking for new strategies to bolster lending capacity and accommodate debt issuances. One such option is term debt....more
On September 18, 2023, the Federal Reserve, Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency jointly published and sought comments on a proposal to implement new, standardized capital...more
On January 16, 2024, the comment period closed for the US banking regulators’ Basel III Endgame proposal. Nearly 200 comment letters were submitted from the financial sector, commercial user, and the general public....more
On 12 December 2023, the UK Prudential Regulation Authority (PRA) published the first of two near-final policy statements on the implementation of revisions to the Basel 3 standards, known in the U.K. as Basel 3.1. This...more
The Prudential Regulation Authority ("PRA") has published its near-final policy statement (the "PS") setting out feedback to seven chapters of its consultation paper 16/22 (CP16/22) on implementation of the final elements of...more
This week, Federal Deposit Insurance Corporation (“FDIC”) Director Jonathan McKernan gave remarks to the ISDA Conference on Trading Book Capital on Basel III Implementation....more
The UK’s banking regulator, the Prudential Regulation Authority (“PRA”) has published a Discussion Paper (DP3/23) covering securitisation bank capital in the context of: (1) the Basel 3.1 output floor and capital requirements...more
Last week, Federal Reserve Board (“FRB”) Governor Michelle Bowman gave a speech entitled Financial Stability in Uncertain Times, focusing on the “financial stability risks and vulnerabilities” she is most focused on....more
On October 20, 2023, the US federal banking regulators announced that they were extending the period for public comment to January 16, 2024 for both the (i) Basel Endgame proposal to significantly revise the risk-based...more
On Monday, Michael Barr, the Federal Reserve Board’s (“FRB”) Vice Chair for Supervision, delivered remarks to the American Bankers Association Annual Convention entitled Capital Supports Lending regarding the Basel III...more
The UK’s banking regulator, the Prudential Regulation Authority (“PRA”) has announced its intention to move the implementation date of the final Basel 3.1 policies by six months to 1 July 2025 and commensurately reduce the...more
The US federal banking regulators recently proposed extensive revisions to the regulatory capital requirements, referred to as the Basel Endgame. The July and August proposals – targeted at banks with $100 billion (or more)...more
As we covered previously, on July 27, 2023, the U.S. prudential bank regulators (the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency (“OCC”)...more
In April 2022, the Basel Committee on Banking Supervision (the Basel Committee) began a review of “the core principles for effective banking supervision” (Core Principles or CP). Last month, the Basel Committee published a...more
On July 27, 2023, the Federal Reserve, FDIC, and OCC issued a notice of proposed rulemaking and request for comment on a proposal (the Proposal) to implement the final components of the Basel III Capital Accords, often...more
In Short - The Situation: The federal banking agencies approved a proposal that would implement a "gold-plated" U.S. version of the "Basel III endgame."...more
On July 27, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (collectively, the agencies) issued a joint notice of proposed...more
The Federal Reserve has announced that its FedNowSM Service, a new interbank settlement service with clearing functionality to support instant payments, went live on July 20 with 35 early-adopting banks and credit unions. The...more