News & Analysis as of

HVCRE Loans Final Rules

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

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