News & Analysis as of

HVCRE Loans Federal Deposit Insurance Corporation

Dechert LLP

Top 10 Things to Know About the Final HVCRE Rule

Dechert LLP on

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

Nutter McClennen & Fish LLP

Bank Report: November 2019

OCC and FDIC Propose Interest Rate Fix for Loans Transferred to Non-Banks - The FDIC and OCC have separately proposed rules that would codify the “valid-when-made” doctrine and clarify that when a bank sells, assigns, or...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

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

Sullivan & Worcester

Congress Introduces Bill to Clarify HVCRE Loans

Sullivan & Worcester on

Eric D. Lemont wrote the article, "Congress Introduces Bill to Clarify HVCRE Loans," which discusses proposed amendments to the Federal Deposit Insurance Act. Specifically, Mr. Lemont describes how the proposed legislation...more

Williams Mullen

“High Volatility” - How Can Banks Avoid Having Loans Classified as HVCRE?

Williams Mullen on

Where did the HVCRE rules come from? In the wake of the 2008 financial crisis, international banking regulators determined that banks were not sufficiently well-capitalized and published the Basel III Capital Accords in...more

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