Client Alert

HVCRE Clarification Finally Arrives – Congress Passes Legislation Addressing Treatment of ADC Loans under the Capital Rules

23 May 2018

On May 22, 2018, Congress passed a financial regulatory reform bill, S. 2155, the “Economic Growth, Regulatory Relief, and Consumer Protection Act” (the “Reform Bill”). Among other things, the Reform Bill clarifies the treatment of acquisition, development, and construction (ADC) loans characterized as high volatility commercial real estate (HVCRE) exposures under the U.S. Basel III capital rules. It is expected that President Trump will soon sign the legislation. This Client Alert provides a summary of how ADC loans will be treated under the Reform Bill once it becomes effective.

Read our client alert.



Unsolicited e-mails and information sent to Morrison & Foerster will not be considered confidential, may be disclosed to others pursuant to our Privacy Policy, may not receive a response, and do not create an attorney-client relationship with Morrison & Foerster. If you are not already a client of Morrison & Foerster, do not include any confidential information in this message. Also, please note that our attorneys do not seek to practice law in any jurisdiction in which they are not properly authorized to do so.