Last week, over 4,200 of our closest friends met virtually for the annual January conference by the Commercial Real Estate Finance Council, which is usually held in Miami. While we have all learned to go without in the last...more
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
The new Opportunity Zones program that came to us in 2017’s major tax reform offers investors the chance to roll the capital gains from the sale of any appreciated property into new investments, located within specially...more
2/14/2019
/ Capital Gains ,
Community Development ,
Economic Development ,
HVCRE ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Redevelopment ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Planning
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
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...more
In seven short years, the Consumer Financial Protection Bureau (CFPB) has managed to court controversy across the political spectrum. Under the leadership of former Director Richard Cordray, the bureau (for better or worse)...more
It’s day 2 of Mark Zuckerberg’s Congressional debut and I still have yet to catch a glimpse of him or his entourage. But – I have had the opportunity, with some fellow industry players, CREFC staff and members of the...more
In case you’ve been too busy sifting through fake news to follow efforts to reform the High Volatility Commercial Real Estate (HVCRE) regulations that affect acquisition, development or construction (ADC) loans, here’s where...more
Add HVCRE reform to the list of things that have bi-partisan support (currently on the list: flag pins and banning the use of Twitter in the White House). On Tuesday, the House passed (with bi-partisan support…which should...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
The Auditing Standards Board (the “ASB”) of the American Institute of Certified Public Accountants recently released new standards as part of the “Attestation Clarity Project” with the goal of redrafting all its standards “in...more