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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) are proposing to amend the regulatory capital rule to revise the definition of “high volatility commercial real estate.

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HVCRE means High Volatility Commercial Real Estate Source Materials – Basel III – Created Final Rule on Risk Based and Leverage Capital Requirements For FDIC Insured Financial Institutions – US Mortgage Bankers Association Letter – Joint Agency Response – Frequently Asked Questions on the

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The Bill would ease capital requirements by allowing a borrower to use the appreciated value of the real property in calculating the 15% capital contribution requirement for an exemption to HVCRE. Finally, the proposed Bill would exempt loans made prior to January 1, 2015.

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In addition to outlining their approach to company-run stress testing and enhanced prudential standards in light of the new regulatory reform law, the agencies today also announced how they intend to approach the implementation of several other provisions of S. 2155.

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Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities Act. Yes No Indicate by check mark if the registrant is not required to file.

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The bill clarifies that a loan may be reclassified as non-HVCRE upon the completion of construction or development and when cash flow generated by the project is sufficient to support debt service.

The U.S. House of Representatives has passed a bill to clarify the rule regarding high volatility commercial real estate loans, commonly referred to as "HVCRE loans." This alert summarizes the major clarifications contained in that bill, H.R. 2148, the Clarifying Commercial Real Estate Loans Act.

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