In case you’ve been too busy sifting through fake news to follow efforts to reform the High Volatility Commercial Real Estate (HVCRE) regulations that affect acquisition, development or construction (ADC) loans, here’s where we are and where we think we are going.
Continue Reading No “Fake News” Here – Just the Facts on HVCRE
HVADC
HVCRE Reform is HOT HOT HOT: Pittenger Bill Progresses to Senate
By Krystyna Blakeslee & Gina Leahey on
Add HVCRE reform to the list of things that have bi-partisan support (currently on the list: flag pins and banning the use of Twitter in the White House). On Tuesday, the House passed (with bi-partisan support…which should bolster its chances of passing in the Senate) H.R.2148 – Clarifying Commercial Real Estate Loans, otherwise known…
Proposed Changes to HVCRE Open for Comment
By Krystyna Blakeslee & Gina Leahey on
At long last (at least for those of us who have been checking the Federal Register daily), the proposed HVADC rule has been published in the Federal Register and is open for comment. The public (that’s us!) has 60 days to comment – so all comments are due by December 26, 2017 (Ho ho ho!). …
Yakety Yak – Talk Back: Regulators Respond to HVCRE Complaints
By Krystyna Blakeslee & Gina Leahey on
On September 27, 2017, the Federal Reserve, FDIC and OCC released a Notice of Proposed Rulemaking (NPR) that they describe as simplifying compliance with certain aspects of the agencies’ risk based capital (RBC) rules to, among other things, replace the standardized approach’s (SA) treatment of HVCRE loans with a simpler treatment for most acquisition, development or construction (ADC) loans called high volatility acquisition, development or construction (HVADC). Spoiler alert: it just replaces vague and confusing rules with a slightly different set of vague and confusing rules.
Continue Reading Yakety Yak – Talk Back: Regulators Respond to HVCRE Complaints