On November 19, 2019, the federal banking agencies issued a final rule (the “Final Rule”) that incorporates a new definition of an “HVCRE exposure” into the U.S. regulatory capital rules. The new definition is substantially...more
On July 12, 2019, the federal banking agencies released a notice of proposed rulemaking (July NPR) regarding the capital treatment of certain loans that finance land improvements but do not finance the construction of...more
As reported in a prior Client Alert, new federal legislation enacted into law on May 24, 2018 narrows the types of acquisition, development, and construction (ADC) loans that may be subject to a heightened risk weight under...more
As reported in a prior Client Alert, financial services reforms enacted into law on May 24, 2018, clarified the treatment of acquisition, development, and construction (ADC) loans characterized as high-volatility commercial...more
On November 7, 2017, the House of Representatives, by voice vote, passed H.R. 2148, the Clarifying Commercial Real Estate Loans Act (the “Bill”). The Bill was reported favorably out of the House Financial Services Committee...more
On September 27, 2017, the three federal banking agencies (the “Agencies”) released a Notice of Proposed Rulemaking (“NPR”), which proposes changes to certain aspects of the bank capital rules under the “standardized...more