Client Alert

Agencies to Conform HVCRE Exposure Definition to New Law

24 Sep 2018

On September 18, 2018, the federal banking agencies jointly issued a notice of proposed rulemaking to revise the definition of a “high-volatility commercial real estate (HVCRE) exposure” to conform to the definition of an “HVCRE ADC loan” in new federal legislation enacted into law on May 24, 2018.  At its core, the notice of proposed rulemaking would simply import the new law’s definition of an HVCRE ADC loan into the capital rules. In addition, the discussion of the proposed rule in the notice of proposed rulemaking addresses some interpretative issues surrounding the new HVCRE ADC loan definition and seeks comments on others.

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.