Last week, the House Committee on Financial Services reported out the Preserving Access to CRE Capital Act of 2016 (the “bill”) in a remarkably bipartisan sort of way (paving the way for: “Well, yes, I did vote for it, but then I voted against it.”). The bill, which was drafted and backed by CREFC, would … Continue Reading
We may be approaching a tipping point where the burden of the new federal regulatory state, purportedly designed to make our economy stronger by making the banking system safer, will begin to demonstrably become a cure that’s worse than the disease. To my eye, much of the new regulatory apparatus feels like political theatre designed … Continue Reading
The 2016 CRE Finance Council Industry Leaders Conference, held this week in Miami, was dominated by two topics– risk retention and liquidity. Almost all the forums, panels and presentations at the conference were overshadowed by the specter of risk retention and more general concerns about liquidity. … Continue Reading
As we do each year at Crunched Credit, we take the end of a calendar year as an opportunity to stop and reflect on where we are, and what the next year might hold. Recognizing the certainty that a successful prediction is more a random event – a blind cat finding a dead mouse, than … Continue Reading
In an uninteresting turn of events last week, Congress has passed the Omnibus Bill, which contained a provision extending the EB-5 program until September 30, 2016, with no other changes to the program. As previously discussed, the last couple of months have been filled with substantial discussions and the introduction of potential legislation aimed at … Continue Reading
Earlier this year we discussed the uncertain future of the EB-5 Visa Program, one of the most successful inbound investment programs of recent years, as evidenced by the $5.2 billion dollars the program has generated in the past ten years alone. Although the EB-5 Visa Program was set to expire on September 30, 2015, Congress … Continue Reading
As is our tradition here at Crunched Credit, each year, about this time, we award our Golden Turkey Awards. Once again, I must say that we are blessed, blessed with so many worthy candidates. Our government, our courts, the regulatory estate both here and in Europe and around the world and the political class in general have … Continue Reading
The way the new Basel III High Volatility Commercial Real Estate Lending Rule (HVCRE) was crafted, and is being enforced, is insane. We’ve written about this before. This is one of the purest examples of the regulatory apparatchik’s mule-headed refusal to look at data or engage with the banking establishment to develop thoughtful and effective … Continue Reading
Frequent subscribers of this blog may remember MiFID I coming into force on 1 November 2007, fundamentally revising the existing rules applicable to, amongst others, European firms providing portfolio management and broker dealer services in the EU.… Continue Reading
As we begin to close in on the initial implementation of the Risk Retention Rule, we are looking beyond the headlines and trying to figure out how the Rule will actually work. The result is troubling.… Continue Reading
The Great Equity Correction of 2015 that is now being enjoyed by all of us is a correction, and not the beginning, of the Great Bear Market of 2015 (from my lips to God’s ears). It reminds me of just how little we know about how all complex systems, like the global financial market (and … Continue Reading
After years of delays, changes and significant debate, the Volcker Rule is now, largely, in full effect. Sold to a sometimes intellectually incurious Congress and the electorate as a central piece of legislation to limit systemic risks to the financial system, the Volcker Rule, among other things, prohibits “banking entities” from engaging in proprietary trading … Continue Reading
For want of a baker, a job was lost. For want of a job, the economy was lost. For want of an economy, the banking system collapsed. For want of a banking system – well, ultimately Grexit. Grexit, Grexit, Grexit, Grexit, Grexit, Grexit, (China), Grexit, Grexit. The Greeks will be fine, right? There is no … Continue Reading
This is a good news story for once. But, of course, since the father of this soupcon of good news is our government, it’s almost unintended. From the ashes of the economic recession of 2008 came the rebirth of the Immigration Investor Program, more commonly known as “EB-5 Visa Program.” This bit of social engineering … Continue Reading
Or perhaps Prometheus had it right in its original form. “Whom the Gods would destroy they first make mad.” Look at what we are doing to construction lending in the name of our seemingly endless safety and soundness crusade. Under the new regulatory capital rules, we have a new asset class; HVCRE or High Volatility … Continue Reading
You know, as an economist, I am a pretty good piano player. I struggle every morning, marinating in the news cycle, to try to understand what’s happened to the US economy and what its impact will be or might be upon the business of commercial real estate finance. We apparently are inching up on the … Continue Reading
Is the Federal Reserve overreaching by broadening the scope of its policies? If extremism in the defense of liberty is (reportedly) no vice, unremitting, continuous undisciplined chatter for the sake of transparency is no virtue. God knows transparency has become the sine qua non of public ethics these days. To be accused of not being … Continue Reading
A securitization community coming off of record issuances in 2014 has entered the new year with a mixture of nerves and optimism. An estimated 6,500 finance professionals and attorneys converged for the 2015 ABS Las Vegas conference. The new risk retention rules, and their impact on CLOs in particular, were on everyone’s lips – to … Continue Reading
Here’s one from left field that I only began to focus on recently. In mid-December, the gnomes of Basel published several “Consultative Documents” on bank capital and credit risk issues. First of all, I’m somewhat suspicious by the open palmed amiability of something called a “Consultative Document.” That suggests a dialogue with regulators but this … Continue Reading
I saw the movie Imitation Game last weekend, which is the story of Alan Turing and his role in breaking the Enigma Code which shortened World War II and saved millions of lives. (Spoiler Alert: He did it, we won.) Turing, played by Benedict Cumberbatch, was terrific, even if you’re not a certified “Cumberbitch.” It … Continue Reading
We here at CrunchedCredit are getting ready, as we do each year at this time, to polish up the palantir and make our predictions and business projections about the coming year. While it can be a fun exercise, it’s actually serious business. To start with, you need a macro view of the geopolitical situation, the … Continue Reading
Who says that Europeans don’t get Halloween? After more than a year in the making, the European Central Bank (“ECB”) just finished its most recent stress test and found that pretty much everything was kinda OK. Sure, a few banks here and there in the nether regions flunked, but perhaps with the exception of that … Continue Reading
After three years of waiting, we now have our Risk Retention Rule. All six of the Agencies responsible for the Rule – the FDIC, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, the Department of Housing and Urban Development, the Federal Housing Finance Agency and the … Continue Reading
By: Daniel Wohlberg and Sean Solis On Sunday, September 21st through Tuesday, September 23rd, almost 3,500 industry insiders descended upon Miami Beach for the 20th annual ABS East Conference at the acclaimed Fontainebleau Hotel. The enthusiasm and excitement was palpable considering the record setting year the market had so far, especially in the CLO space. … Continue Reading