The commercial real estate finance industry is facing substantial challenges due to climate change, particularly with respect to extreme flooding. As flood events continue to occur more frequently and with greater severity across the US, the role of the Federal Emergency Management Agency (FEMA)—and its administration of the National Flood Insurance Program (NFIP) and
February 2020
Quick Note: The NY Fed is Publishing Compounded SOFR Screen Rates
By Crunched Credit on
The Federal Reserve Bank of New York announced last week that it will be publishing “Average SOFR” for 30, 90 and 180 days on its website starting on March 2, 2020. The confusing thing about this announcement is that the Fed has named these rates the “SOFR Averages” when the rates clearly use the ISDA…
Life in the Time of Conferences: CREFC, CREF and SFA
By Rick Jones & Crunched Credit on
With apologies to Mr. Marquez for repurposing the title of his haunting book, it’s conference season here in CRE and ABS securitization-land and therefore a time to reflect (more Marquez) on the risks that the world will become more disorderly, or whether we will progress gently from a perfectly fine 2019 to 2020. We attended CREFC in Miami, are currently attending MBA CREF in San Diego and SFA in Las Vegas (as mere vendors, we don’t get to go to Beaver Creek, more’s the pity). After having seen thousands of our best friends, we’ll have a pretty good sense of what the market thinks of 2020. We’ve already published our outlook for the year, but now we test it against the wisdom of the crowd (or perhaps herd is closer to the mark).
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Top 10 Things to Know About the Final HVCRE Rule
By Krystyna Blakeslee & Gina Leahey 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 Volatility Commercial Real Estate (HVCRE) regulations that affect acquisition, development or construction (ADC) loans made by banking organizations that are subject to the capital rule, including bank holding companies, savings and loan holding companies and U.S. intermediate holding companies of foreign banking organizations. The Final HVCRE rule becomes effective April 1, 2020. Here are the Top 10 takeaways from the Final HVCRE Rule:
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