In an earlier posting, I commented on what I call the "delegated legislation" approach taken by Congress in the Dodd-Frank Wall Street Reform and Consumer Protection Act. By that, I mean Congress cobbled together pages and pages of a new law, and in it told the Federal Regulators "this is what I generally envision, now go… Continue Reading
Tag Archives: regulatory guidance
CRE Workouts: Early Signs Of Banks Implementing the ‘Good’ Note A and ‘Bad’ Note B Approach?
Posted in Market Trends, Tough Times for LendersPreviously, we commented on the October 30, 2009 regulatory announcement by Federal regulators, which articulated a significant switch or approach in the handling of distressed commercial mortgage loans. [links to two blog postings, including a copy of the announcement] One startling portion of the announcement is that banks are encouraged, in the appropriate circumstances, to… Continue Reading
Regulators Issue Major Regulatory Announcement: A Prudent Peace Pipe?
Posted in Good Times for Lenders, Market Trends, Remedies, Tough Times for Lenders, Workout IssuesThis past Friday (October 31, 2009), the Federal Financial Institutions Examination Council (website) released a major policy statement giving guidance, and articulating general principals, for the distressed commercial real estate debt market. The report is a "must" read: PDF. (Footnote #1 to the report lists the Federal & State Regulators – visit the FFIEC website for the complete… Continue Reading