News & Analysis as of

Commercial Real Estate Market Office of the Comptroller of the Currency

Cozen O'Connor

Cozen Currents: The General Election Begins

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The Cozen Lens- •With Super Tuesday, the State of the Union, and the release of President Biden’s FY25 budget, this past week has been a politically consequential one. This series of events mark the pivot to the general...more

McGlinchey Stafford

Federal Agencies Issue Joint Policy Statement for Commercial Real Estate Loan Workouts

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On June 29, 2023, the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and National Credit Union Administration (the agencies) jointly issued...more

Amundsen Davis LLC

Insights from the OCC Semiannual Risk Perspective

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On June 14, 2023, the Office of the Comptroller of the Currency (OCC) published its Semiannual Risk Perspective which identifies key issues facing the federal banking system. This highly anticipated report comes in the wake...more

Morrison & Foerster LLP

Regulators Replace Policy Statement on Troubled CRE Loans and Allow Short-Term Accommodations

The Board of Governors of the Federal Reserve System, Office of the Comptroller of the Currency, National Credit Union Administration, and Federal Deposit Insurance Corporation (collectively, the “Agencies”) issued a joint...more

Cadwalader, Wickersham & Taft LLP

Banking Agencies Finalize Interagency Policy Statement on CRE Loan Workouts

On June 30, the Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”), Office of the Comptroller of the Currency (“OCC”) and the National Credit Union Administration (“NCUA”) finalized their Policy...more

Dechert LLP

Federal Regulators Adopt a New Policy Statement on Prudent Commercial Real Estate Loan Accommodations and Workouts

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The OCC, FDIC, NCUA and Fed have adopted a new Policy Statement on Prudent Commercial Real Estate Loan Accommodations and Workouts. The new policy statement updates, expands on and supersedes existing guidance from 2009,...more

Dechert LLP

Top 10 Things to Know About the Final HVCRE Rule

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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

Orrick - Finance 20/20

Federal Banking Agencies Issue Final Rule to Exempt Commercial Real Estate Transactions of $500,000 or Less from Appraisal...

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On April 2, 2018, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency issued a final rule that increases the threshold for...more

Goodwin

Financial Services Weekly News - April 2018

Goodwin on

Editor's Note - Treasury Issues Recommendations to Modernize the Community Reinvestment Act. On April 3, the U.S. Department of the Treasury released a report containing its recommendations for modernizing the Community...more

Steptoe & Johnson PLLC

Proposed Regulatory Updates Will Require Increased Analysis of New Loans to Determine if Different Risk Weight Exposures Apply

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On September 27, 2017, the principal federal banking agencies, the Board of Governors of the Federal Reserve, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency, released a Notice of...more

Holland & Knight LLP

West Coast Real Estate Update: November 2016 #2

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California Appellate Court Overturns “Sham Guaranty” Defense - The single-purpose entity (SPE) has become a ubiquitous tool in commercial real estate acquisitions and financing in California. Lenders increasingly require...more

King & Spalding

Washington Insight - September 2016

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House Financial Services Committee Votes To Repeal And Replace Dodd-Frank - On September 13th, the House Financial Services Committee approved the Financial CHOICE Act of 2016 to repeal and replace key parts of the 2010...more

King & Spalding

OCC Wants Lenders To Tighten Up Standards For Commercial Real Estate Loans

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According to its Semiannual Risk Perspective for Spring 2016 (the “Semiannual Risk Report”), the National Risk Committee of the Office of the Comptroller of the Currency (the “OCC”) has escalated its oversight of commercial...more

JD Supra Perspectives

Selected Risk Retention Questions and Answers for CMBS Securitizations

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On October 22, 2014, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Securities and Exchange Commission, the Federal Housing...more

Bryan Cave Leighton Paisner

Interagency CRE Guidance Update

In the ancient world kings and emperors regularly sought advice from the Oracle at Delphi when making important decisions. The Oracle would respond to questions, sometimes in poetry, other times in prose, in a manner that...more

Manatt, Phelps & Phillips, LLP

Regulators Caution Banks About CRE Lending

Why it matters - In a statement expressing concern about the growth of commercial real estate (CRE) lending, the federal banking agencies stressed the need to utilize "prudent risk-management practices." The Board of the...more

Dechert LLP

Risk Retention Follies - Part Deux

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Well, Halloween has come and gone and with the annual bacchanal of faux frisson over zombies, vampires and the like behind us, can we also put away risk retention anxieties like one of those annoying and morally disturbing...more

Winstead PC

OCC’s Commercial Real Estate Lending Handbook: Misses the List on Legal Issues

Winstead PC on

Over the last few weeks, I’ve commented on the new version of the OCC’s Commercial Real Estate Lending Handbook (I give it a gentlemen’s C); and I listed a few legal topics that deserve some guidance from the OCC. ...more

Winstead PC

Grading the Examiners: OCC’s Commercial Real Estate Lending Handbook gets a “C”

Winstead PC on

Last month, the Office of the Comptroller of the Currency published the Commercial Real Estate Lending handbook (August 2013). The 128 page handbook gives guidance to bank examiners and bankers on risks inherent in...more

Katten Muchin Rosenman LLP

OCC Revises Guidance on Commercial Real Estate Lending

On August 20, the Office of the Comptroller of the Currency (OCC) issued the “Commercial Real Estate Lending“ booklet of the Comptroller’s Handbook to replace the OCC’s “Commercial Real Estate and Construction Lending”...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - August 23, 2013

In this issue: - SEC, CFTC and FINRA Issue Joint Advisory on Business Continuity and Disaster Recovery Planning - FINRA Updates Private Placement Form and Issues FAQ - SEC Approves Amendments to FINRA...more

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