HVCRE: The Continuing Saga of Lenders
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
The Economic Growth, Regulatory Relief, and Consumer Protection Act (the “Act”), signed into law on May 24, 2018, with immediate effect, amended multiple provisions of Dodd-Frank, including the capital requirements for loans...more
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
On May 22, 2018, Congress passed a financial regulatory reform bill, S. 2155, the “Economic Growth, Regulatory Relief, and Consumer Protection Act” (the “Reform Bill”). Among other things, the Reform Bill clarifies the...more
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