Conspiracy theory fans, tin-foil hat wearers everywhere, Nostradamus wannabes, the broadly unhinged and, of course, our professional purveyors of doom and gloom roosting on evening cable news see patterns where there are none, embrace straight-line projections based on disparate and unrelated data and loudly and often shrilly bleat that the end is nigh. That’s all … Continue Reading
The current administration’s legislative initiatives are largely bottled up in a split Congress, so the path toward achieving the White House’s policy priorities runs almost exclusively through the executive order and rule-making process and boy, have they worked it hard. But Santa is coming down the chimney delivering lumps of coal so often these days, … Continue Reading
Each year about this time, I sit down and try to cobble together predictions for the performance of the economy and the performance of the CRE market in the coming year. Of course, I’m wrong every time. It’s not for lack of trying. I do try to think hard about where we’ve come, what things … Continue Reading
Events keep happening that really do make it clear that we are about to enter a period of enhanced regulatory intrusion into the financial services space. Shocking! And entirely unexpected, right? (You’re winning, sir) While that is in many respects troubling, it’s also the stuff of opportunity for the creative and nimble. I’ll explain.… Continue Reading
The Great Index Reformation is coming. (I note in passing that the last Reformation led to the 100 Years War…just saying.) This is a massive change to our market that did not bubble up from the great unwashed on the barricades demanding change, but something that has been driven from the regulatory heights. More a … Continue Reading
It’s coming up on awards season. The Emmys were last week and weirdly, I got a thought bubble about nominees in the Black Swan category, walking the red carpet looking for attention! Think the Masquerade scene from Phantom of the Opera when the Phantom comes prancing down the stairs to harsh the festivities (at least … Continue Reading
Happy Inauguration Day (I hope). Every turning of the year makes for a convenient point to look backwards, and of course, forward, but this year seems to actually denote some sort of inflection point and, as a card-carrying member of the blogosphere, I feel compelled to burden you with my views as to what the … Continue Reading
Since nothing is happening in the news right now, we thought we would put out a second post on LIBOR this week. As you may know, Dechert has a LIBOR podcast which you can find on our YouTube page. In the latest episode, David Bowman, Senior Associate Director from the Board of Governors of the … Continue Reading
After much anticipation and expectation, on June 25, 2020, the Federal Reserve Board, CFTC, FDIC, OCC, and SEC (the “agencies”) finalized an amendment to Section 13 of the Bank Holding Company Act, commonly known as the Volcker Rule, which among other things prohibits banking entities from sponsoring or acquiring ownership interests in “covered funds.” Covered … Continue Reading
The spread of COVID-19 has created a new reality for the hospitality industry. As of March 25, the CDC reported 54,453 confirmed cases in the U.S., and the number is expected to grow exponentially. In the hopes of slashing infection rates, governments have implemented international travel bans, shelter-in-place orders and other restrictive measures. The second-most … Continue Reading
Trigger Warning: If any of you, my readers, or your senior management, who might actually read this, are card carrying members of the global elite, please be assured that I am only talking about other people here. This season of election insanity, where only big ideas packaged in often eye rolling tropes have their day … Continue Reading
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 … 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 utterly blessed with so many worthy candidates. The truly deserving have once again wrangled with vision and astounding persistence to earn a spot on our acclaimed list. To … Continue Reading
Back in the febrile, hyperventilated times that birthed the Dodd-Frank Wall Street Reform and Consumer Protection Act (blessedly known simply as Dodd-Frank), one of the issues that energized the activists’ intent on “fixing” what was wrong was the notion that the ratings agencies were complicit in the overpricing of financial assets. In a “want for … Continue Reading
Long ago, I read a book by a man named Herman Kahn, one of the founders of the Hudson Institute and a well-known public intellectual. The book was entitled On The Year 2000. (He was more famous for that truly uplifting missive, On Thermonuclear War.) I suspect I didn’t understand a lot of it, but … Continue Reading
Tim Sloan resigned as the CEO of Wells Fargo a few months ago. I had briefly worked with Tim and much admired him so, on a personal level, this was sad. Now, Mr. Sloan’s resignation might have been a compelling and obvious move in any crisis consultant’s playbook, so I get that – but – … Continue Reading
Beany & Cecil was a cartoon. The Current Expected Credit Loss accounting rules, better known as CECL, which the FASB is insisting will go into effect at the beginning of next year for publicly traded banks and lenders and a year later for all other GAAP reporting entities is not. Now, heaven forfend that I … Continue Reading
God help me, I’m finally writing about climate change. This commentary assiduously avoids the obviously political (we take the view that complaining about and belittling our elected representatives and the permanent bureaucracy for doing boneheaded things is entirely apolitical). And while even the phrase “climate change” carries with it a certain frisson of a capital … Continue Reading
On March 15, the day the Japanese Financial Services Agency (the “JFSA”) published its final risk retention rules, Dechert’s CLO team published an OnPoint discussing the new final Japanese risk retention rules and their impact on the CLO market. … Continue Reading
We are all going to be heartedly sick of discussing LIBOR and LIBOR transition long before it becomes a thing at the end of 2021, but we really need to get this done. I can’t make this at all funny. We have a problem…but not a solution. Fixing it is going to be a heavy … Continue Reading
We’re all just back from CREFC and the mood was broadly constructive. (Don’t you love that word, “constructive”? When did “constructive” become a fancy way to say “good”?) We all went to South Beach this year wondering where the investors were, wondering whether the market was okay and wondering whether December was a blip or … Continue Reading
It’s 2019. Nothing really terrible or shocking has happened yet…at least by the standards of December. But it’s early yet. As a card-carrying member of the commentariat, I could not possibly pass up the opportunity to bloviate on the “Year Ahead” with the certain knowledge that no one will remember if I’m wrong, and if … Continue Reading
It’s that time again for Dechert’s CrunchedCredit Annual Golden Turkey Awards. In a year made most remarkable by the extraordinary performance of the US economy, idiocy, silliness, pigheadedness and stupidity have tended to be somewhat obscured by the economic good news machine. At the other end of the spectrum, the continued high volume of outrage … Continue Reading
With full and complete credit to the Bard (Macbeth), and to Mr. Ray Bradbury who repurposed this line as the title for his 1962 dark fantasy (of which I was and still am a huge fan), there is just not a better title for this note. Trust me. A few weeks ago, I inked a … Continue Reading