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HVCRE ADC Update: Regulators Propose Eliminating Exemption for Land Development Loans

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

Proposed Changes to HVCRE Open for Comment

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

Yakety Yak – Talk Back: Regulators Respond to HVCRE Complaints

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

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