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Financial Institutions › HVCRE

Amundsen Davis LLC

Relax! Navigating High Volatility Commercial Real Estate Exposure Just Got Easier

Amundsen Davis LLC on

In analyzing the causes and effects of the 2008 financial crisis, banking regulators concluded that banks were not adequately capitalized to support many of their lending practices, including making high volatility commercial...more

Morrison & Foerster LLP

Long Awaited HVCRE Rule Clarifies Capital Treatment of Certain Real Estate Loans

Morrison & Foerster LLP on

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

Dechert LLP

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

Dechert LLP on

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

Morrison & Foerster LLP

Federal Banking Agencies Release New NPR Expanding HVCRE Proposed Rule

Morrison & Foerster LLP on

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

Cozen O'Connor

Navigating Improved Rules for HVCRE Loans – What You Need to Know

Cozen O'Connor on

On May 24, 2018, the Economic Growth, Regulatory Relief and Consumer Protection Act (the Economic Growth Act or the Act, as applicable) was signed into law. Section 214 of the Economic Growth Act contains provisions that...more

Morrison & Foerster LLP

Agencies to Conform HVCRE Exposure Definition to New Law

Morrison & Foerster LLP on

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

Dechert LLP

HVCRE (The Reformed Loan): Musings and Next Steps

Dechert LLP on

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

Stinson LLP

HVCRE Relief for Lenders

Stinson LLP on

In the wake of the 2007-2008 financial crisis there was a heightened focus on the risk management and capital adequacy requirements of financial institutions. As a result, the concept of High Volatility Commercial Real Estate...more

Buchalter

Feds Ease Regulation of High Volatility Commercial Real Estate (HVCRE) Lending

Buchalter on

On May 24, 2018, the Economic Growth, Regulatory Relief, and Consumer Protection Act (the Act) took effect and, among other things, eased some of the restrictions on bank lending involving what is referred to as high...more

Vedder Price

Regulatory Relief: It’s About Time

Vedder Price on

In November 2016, with the election results confirmed, the banking industry was awash in hopes for a more lenient regulatory posture. To date, the industry has seen no reform. However, on March 14, 2018, the Senate passed and...more

Steptoe & Johnson PLLC

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

Steptoe & Johnson PLLC on

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

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