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Passing the Stress Test: Federal Reserve Turns Focus to Commercial Real Estate
Earlier this year, the Federal Reserve released a broad description of criteria for its 2017 “stress test,” which is meant to measure how well the largest U.S. banks would fare in a financial crisis like the one in 2008. This year, the Fed is putting a larger focus on commercial real estate and even banks […]
Read MoreAppraisal Reliance Language From the Appraiser’s Perspective
What happens when a lender requests reliance language that increases the appraiser’s liability risk? Lenders engaged in securitizing or syndicating commercial and multifamily property loans require some sort of reliance language in an appraiser’s reports. Likewise, all lenders have an obligation to themselves and their customers to ensure that an appraiser’s report can be relied upon. […]
Read MoreHighlights of Interagency* and Agency Actions to Reduce Regulatory Burden
The following are selected highlights from the agencies’ responses to issues raised by EGRPRA commenters to reduce regulatory burden, especially on community banks. Simplifying the capital rules The agencies are developing a proposal to simplify the generally-applicable framework. Such amendments likely would include: Replacing the framework’s complex treatment of high volatility commercial real estate (HVCRE) […]
Read MoreCommercial Appraisal Threshold Could Be Raised
U.S. bank regulators are considering easing commercial real estate appraisal requirements, a move that could benefit borrowers. Regulators have concluded that the threshold for mandatory appraisals on commercial property, which hasn’t been raised since 1994, should be increased from $250,000 to $400,000. The residential threshold of $250,000 would remain unchanged. Small Business Borrowers Benefit The […]
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