HVCRE: The Continuing Saga of Lenders
Last week, the US federal banking regulators proposed changes to the enhanced supplementary leverage ratio (“eSLR”) requirement for US global systemically important bank holding companies (“US GSIBs”) (the “Proposal”)....more
On Tuesday, September 10, the Federal Reserve announced a reproposal of the much discussed and awaited Basel III Endgame. However, before we dive into the reproposal, it is important to take a step back and look at how we got...more
On September 18, 2023, the Federal Reserve, Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency jointly published and sought comments on a proposal to implement new, standardized capital...more
As we covered previously, on July 27, 2023, the U.S. prudential bank regulators (the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency (“OCC”)...more
On July 27, 2023, the Federal Reserve, FDIC, and OCC issued a notice of proposed rulemaking and request for comment on a proposal (the Proposal) to implement the final components of the Basel III Capital Accords, often...more
In Short - The Situation: The federal banking agencies approved a proposal that would implement a "gold-plated" U.S. version of the "Basel III endgame."...more
On July 27, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (collectively, the agencies) issued a joint notice of proposed...more
As we are coming to a close on 2022, we’re taking a look back at some of the important developments of 2022 and what lies ahead for 2023. Looking Back at 2022 - As past readers may have seen me say before, there’s a...more
Where did the HVCRE rules come from? In the wake of the 2008 financial crisis, international banking regulators determined that banks were not sufficiently well-capitalized and published the Basel III Capital Accords in...more
Amendments to Offshore Fund Rules to Reflect Finance Act 2014 AIFM Partnership Tax Changes - Regulations amending the Offshore Funds Regulations 2009 (the 2009 Regulations) to reflect the Finance Act 2014 changes to...more
The FRB Issues Final Basel III Capital Reform Rule - On Tuesday, July 2, 2013, the Federal Reserve Board (the “FRB”), in coordination with the Federal Deposit Insurance Corporation (the “FDIC”) and the Office of the...more