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U.S. federal banking agencies recently published the “Final Rule” that incorporates a new definition of an “HVCRE [high-volatility commercial real estate] exposure” into the U.S. regulatory capital rules. For loans that originated after January 1, 2015 and before April 1, 2020, banking organizations have the option of maintaining their current capital treatment, or reevaluating the loans under the revised HVCRE exposure definition.

Long Awaited HVCRE Rule Clarifies Capital Treatment Of Certain Real Estate Loans

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U.S. federal banking agencies recently published the “Final Rule” that incorporates a new definition of an “HVCRE [high-volatility commercial real estate] exposure” into the U.S. regulatory capital rules. For loans that originated after January 1, 2015 and before April 1, 2020, banking organizations have the option of maintaining their current capital treatment, or reevaluating the loans under the revised HVCRE exposure definition. Henry Fields and Mark Sobin of Morrison & Foerster’s Financial Services group discuss the details of the “Final Rule” in the latest edition of <a target="_blank" href="http:https://media2.mofo.com/v3/assets/blt5775cc69c999c255/blt539e7a224c3c0f2f/6273ed41b5ad5f2863c5ac6d/200300-hvcre-rule-loans.pdf">The Banking Law Journal</a>.

Long Awaited HVCRE Rule Clarifies Capital Treatment Of Certain Real Estate Loans

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Henry M. Fields

Senior Counsel

Financial Services