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 31, the U.S. House Committee on Financial Services wrote to the Chair of the Fed, Jerome Powell, urging him to withdraw and re-propose the Basel III Endgame proposal. In its letter, the Committee argues that the Fed’s...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
Because banks receive favorable capital treatment when a credit facility’s tenor is shorter than one year, lenders increasingly offer financing with 364-day tenors and uncommitted extension option terms of up to 364 days. In...more
On March 5, the Chairman of the House Financial Services Committee, Patrick McHenry (NC-10), along with all Republican members released a letter to Federal Reserve Chairman Jerome Powell, Acting Comptroller of the Currency...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
On January 26, 2024, the US federal banking regulators announced proposed reporting changes to implement the Basel III Endgame requirements. This may come as a surprise to the many banking organizations and others, who only...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 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 Bank of England has published a Policy Statement on the Implementation of the Basel 3.1 standards in the U.K., taking account of responses to its Consultation Paper 16/22 published in November 2022. The Basel 3.1 changes...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 regulators (primarily the Prudential Regulation Authority) are currently reviewing consultation responses received on the proposed implementation of Basel 3.1 in the UK, with the final rules being published between...more
This week, the Senate Banking Committee and the House Financial Services Committee held oversight hearings with leaders of the Federal Deposit Insurance Corporation (“FDIC”), Federal Reserve Board (“FRB”), the National Credit...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 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
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