HVCRE: The Continuing Saga of Lenders
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
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
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
Miller Canfield participated in the Commercial Real Estate Finance Council (CREFC) Winter Conference in Miami in January 2019. The conference offers a candid insider’s view that looks both backward and forward and has proven...more
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
Editor's Note - In This Issue. The Board of Governors of the Federal Reserve System (Federal Reserve), the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (together, the Federal...more
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
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
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
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
As we mentioned just a couple of weeks ago, the federal banking regulators have taken aim at the risk weighting rules for High Volatility Commercial Real Estate (“HVCRE”) loans that went into effect back in 2015. In a...more
Bryan Cave attorney Jerry Blanchard joins hosts Jonathan Hightower and Rob Klingler in the studio today to discuss High Volatility Commercial Real Estate (HVCRE) loans....more
We have written several times about the rules concerning the appropriate risk weighting for High Volatility Commercial Real Estate (“HVCRE”) loans. The interagency FAQ published on April 6, 2015 provided some guidance but...more
Welcome and thank you and our listeners and welcome to the first in our series on the national and commercial estate market. My name is David Adams and today I’m talking with Dan Weede – a guy who needs no introduction in...more
By now, anyone who works in the real estate industry is likely to have heard of Basel III and the new requirements for HVCRE Loans. But you may be asking: what is Basel III; what constitutes an HVCRE Loan; and what is the...more