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Tag Archives: Financial Reform

Use ABA Tool To Track Dodd-Frank Changes (Risk Retention; Concentration Limits; etc.)

By Keith Mullen on Posted in Good Times for Lenders, Market Trends, Technology (including Green Buildings)

The Dodd Frank Act (summaries) is the most significant Federal legislation in the last X years  . . . or just in a long, long time.  Central in the Act is the role given to Federal regulatory agencies to create the detailed rules to implement the Act, in what I call "delegated legislation."   The… Continue Reading

Credit Crisis: How Will Bipartisan Panel’s Plan Impact Investment Markets? (and a reminder on “how” we landed in this deep ditch)

By Keith Mullen on Posted in Good Times for Lenders, Market Trends, Tough Times for Lenders

Yesterday, the chairmen of the bipartisan commission on reducing the national debt released an outline (link to report and an example) on spending cuts and tax increases.  The plan focuses on deep cuts in domestic and military spending, an increase in the federal gasoline tax, simplifying the tax code, and benefit cuts and increased retirement age… Continue Reading

Financial Reform Bill Update: House Staff Summary of the Conference Committee Bill is a MUST Read

By Keith Mullen on Posted in Good Times for Lenders, Market Trends

Earlier this week, I posted a short summary of the Financial Services Reform Bill.   Since then, the House Financial Services Committee posted the text of the overhaul agreed by the House-Senate Conference Committee late last week: Now called the Dodd-Frank Wall Street Reform and Consumer Protection Act, the bill is both long (2,193 pages), and… Continue Reading

Financial Reform Bill Update: Initial Summary of Important Provisions

By Keith Mullen on Posted in Good Times for Lenders, Market Trends

Everyone should be following (just read the front page of your local paper) the joint House-Senate conference committee [prior posts] as they work on the financial regulatory reform legislation. On Friday, June 25th, the committee reached agreement on the legislation, with the goal of a House vote on it before the July 4th recess. No doubt,… Continue Reading

The CREF-C June ’10 Convention: A Short Summary With Comments

By Keith Mullen on Posted in Good Times for Lenders, Market Trends, Tough Times for Lenders

(This is my last blog covering the CREF-C June Convention) Below is a very random collection of information (and comments) as “take aways” from my attendance at this convention earlier this week. You’ll note that I really don’t jump into the CMBS 2.0 panels, nor into the special servicing panels. Why? Most of the content from those… Continue Reading

Proposed Legislation To Aid Community Banks In CRE Lending, Delinquent Loans & REO Properties

By Keith Mullen on Posted in Good Times for Lenders, Market Trends

Overlooked by the recent focus on health care reform, and now by the financial reform bills (see my recent blog posts, is draft legislation prepared by Representative Minnick(D-Idaho). Known as "The Community Bank and Commercial Real Estate Stabilization Act of 2010," his draft legislation has circulated on the Hill but has NOT been introduced into… Continue Reading

Financial Reform Bill Update: Helpful Comparison of House & Senate Bills; Conference Committee Taking Shape; Final Hope For Covered Bonds

By Keith Mullen on Posted in Covered Bonds, Good Times for Lenders, Market Trends

The tentative time line for the House-Senate reconciliation conference committee covering the financial regulatory reform legislation is the following: begin to meet during the week of June 7, 2010, with the goal of having a final Bill ready for the President’s signature by the July 4 recess. With that quick time line in mind, here… Continue Reading

MBA Servicing & Tech Conference (Day 1): Federal Legislation; REMIC Rules; FDIC Safe Harbor; & Regulation AB

By Keith Mullen on Posted in Good Times for Lenders, Market Trends, Tough Times for Lenders

(Blogging from the MBA Servicing & Technology Conference . . . ) One phrase describes the majority of the content today at the sessions attended by me at the MBA Servicing & Technology Conference:  "Change is now . . . we just don’t know all of the details." My take away is that some very significant work… Continue Reading

Rating Agency Reform: Summary of the House Bill, Recent Amendments to the Senate Bill & Missing Pieces

By Keith Mullen on Posted in Good Times for Lenders, Market Trends

As I’ve previously noted, rating agency reform is on the table and gaining momentum in the Senate.  The original Senate reform bill (the Restoring American Financial Stability Act (S. 3217)) included an increase in the oversight of the recognized credit rating agencies (referred to as the National Recognized Statistical Rating Organizations or "NRSROs").  Under the Senate reform bill,… Continue Reading

Housing Finance Reform: Obama Administration Takes Two Moves, Supports Fannie & Freddie, and Plans a Road Show

By Keith Mullen on Posted in Good Times for Lenders, Market Trends

On Wednesday, April 14, the White House and the HUD Secretary Shaun Donovan both took steps in support of reforms for the housing market (including Fannie Mae and Freddie Mac).  Here is a quick summary:  White House Asks Public Input on 7 Questions:  The Obama Administration issued a press release asking for public comment on seven questions,… Continue Reading

CRE Financial Reform And Market Trends: Opportunity For New Lending But More Extend & Pretend As Defaults Grow

By Keith Mullen on Posted in Covered Bonds, Good Times for Lenders, Market Trends

James Ruiz recently wrote a piece, published in the Texas Lawyer, summarizing the February 10, 2010 report (“Commercial Real Estate Loses and the Risk to Financial Stability”) issued by the Congressional Oversight Panel. (continue reading link below). It is a good summary of the Panel’s perspective of the credit problems in commercial real estate, and addresses the… Continue Reading

Senate Banking Committee Amends and Passes Reform Bill; CMSA Updates Its Summary and MBA Sees Risk Retention Problems

By Keith Mullen on Posted in Good Times for Lenders, Market Trends

On Monday (March 22, 2010), the Senate Banking Committee voted along party lines and passed the "Restoring American Financial Stability Act of 2010" (with a 13 to 10 vote).  So, Senator Dodd’s financial reform bill makes its way out of the Senate Banking Committee.  And now the bigger battle begins. But not before Committee members… Continue Reading

Senate Banking Committee Releases Financial Reform Legislation (Restoring American Financial Stability Act of 2010): CMSA Summary

By Keith Mullen on Posted in Good Times for Lenders, Market Trends

On Monday, March 15, the Senate Banking Committee released it’s draft of the "Restoring American Financial Stability Act of 2010" [click name to download it].  It is long: 1336 pages. And no surprise at this: it is complicated. Provisions include creation of a consumer protection watchdog housed in the Federal Reserve; creation of a nine-member Financial… Continue Reading

CMBS 2.0 & Financial Reform: Industry Comments on FDIC ‘Safe Harbor’ Provisions For Securitization

By Keith Mullen on Posted in Good Times for Lenders, Market Trends

Yesterday, the Commercial Mortgage Securities Association (CMSA) submitted a comment letter [download] to the FDIC concerning the FDIC’s ‘Safe Harbor’ rule [down load the FDIC's Advanced Notice of Proposed Rulemaking] covering the securitization of commercial real estate loans.  Of course, the CMSA is not the only industry organization to comment on the FDIC’s proposed rule.  For… Continue Reading

MBA-CREF Convention (Day 2): Three Perspectives; Wish List Points to a Slow 2010

By Keith Mullen on Posted in Good Times for Lenders, Market Trends, Tough Times for Lenders

 One take-away for me from the second day of the convention is this: while the three different perspectives (below) point to 2010 being a better or different year than 2009, it will be far from “normal” (when compared to 1994-2004). The Mortgage Banker: relieved The general sense or mood of the mortgage bankers is that… Continue Reading

CMBS Scorecard: Financial Reform Bill – Only A Band Aid For Now; Covered Bonds Later?

By Keith Mullen on Posted in Good Times for Lenders, Market Trends

(Part of my series on the capital markets.  Use the term "scorecard" in the search function on the lower right side of this page to find other postings in this series.) On December 11, the US House of Representatives passed the financial reform bill. As I’ve noted before, "tying" the loan originator or some other responsible party… Continue Reading

Capital Market Scorecard: Financial Services Committee hearing – Covered Bonds testimony

By Keith Mullen on Posted in Good Times for Lenders, Market Trends

The CMSA has published the text of the testimony by Christopher Hoeffel, from his appearance yesterday before the US House Financial Services Committee.  As noted in my posting earlier this week (link), the Committee is investigating the use of the "covered bond" product as one tool to revive the CRE capital markets (and solve some of… Continue Reading

Capital Market Scorecard: Hope on the Horizon – Congressional Hearings on Covered Bonds

By Keith Mullen on Posted in Good Times for Lenders, Market Trends

More on my series commenting on the CMBS loan market and the broader capital markets for commercial real estate . . . . Previously, we’ve brought to your attention a type of commercial real estate debt structure that HAS worked in the EU (for hundreds of years), and it HAS been tried at least twice in… Continue Reading