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.
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Risk Retention Rule
Risk Retention: Flash – These Rules Don’t Work!
By Rick Jones on
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.
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Risk Retention and Stockholm Syndrome
By Rick Jones on
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 SEC – have finally managed to agree, albeit with significant dissent at the FDIC and the SEC, on a Final Rule. Note that Richard Cordray of the Congregation for the Doctrine of the Faith (in Progressive Causes) …er…the Consumer Financial Protection Bureau, apparently had a heavy finger on the scales, which is why there was material dissent at the FDIC and SEC. So, after all those years of waiting, we have “it.” “It” of course is another five hundred some odd pages of commentary and bloviating and a relatively few pages of actual Rule which, as we study it more, will inevitably have left much that will need to be subsequently clarified. We have already found technical inconsistencies between the commentary and the Rule.
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