Lender’s Approach to Commercial Real Estate Loan Extensions and Restructurings Under the June 2023 Policy Statement, Part II
Part II—The Guardrails the Lender Should Stay Within for CRE Loan Extensions and Restructurings.
The Law Of Banking
Lender’s Approach to Commercial Real Estate Loan Extension and Restructuring Under the June 2023 Policy Statement, Part III
Part III — What Lenders Should Look for in the Borrower’s Presentation and Plan.
Lender’s Approach to Commercial Real Estate Loan Extensions and Restructurings Under the June 2023 Policy Statement, Part I
Part I— The Lender’s Assembly of Information for CRE Loan Extensions and Restructurings.
CTA and Customer Due Diligence: CTA's Impact on Financial Institutions
The new Corporate Transparency Act ("CTA"), as part of the National Defense Authorization Act ("NDAA"), directs the Financial Crimes Enforcement Network ("FinCEN") to establish and maintain a national registry of corporate […]
CTA Alert: FinCEN Extends Reporting Deadline for Reporting Companies Formed or Registered in 2024
On November 30, 2023, the Financial Crimes Enforcement Network (FinCEN) issued a final rule extending the deadline for certain "reporting companies" to file their initial beneficial ownership (BOI) report under the Corporate Transparency Act […]
Borrower, Have You Started Preparing for Your Meeting With Your Lender to Discuss a Loan Extension or Restructuring? Part III
In Part II, Charles Aster discussed how the borrower needs to approach the initial meetings with the lender when its CRE loan is in the near future maturing and the borrower needs a loan extension or restructuring. The borrower needs to understand the […]
Borrower, Have You Started Preparing for Your Meeting With Your Lender to Discuss a Loan Extension or Restructuring? Part II
In Part I of this three-part blog on meeting with your lender, Charles Aster discussed the new June 2023 Policy Statement (the "2023 Fed Policy Statement") issued by the Federal Banking Authorities (the “Feds”), the upcoming […]
Borrower, Have You Started Preparing for Your Meeting With Your Lender to Discuss Loan Extension or Restructuring? Part I
As discussed in previous blogs regarding the $4-5 Trillion of office mortgage loans maturing in 2024 and 2025, the Federal Banking Authorities (the “Feds”) have foreseen, in their new June 2023 Policy Statement (the "2023 Fed Policy […]
Corporate Transparency Act – The Access Rule
The Corporate Transparency Act ("CTA") directs the Financial Crimes Enforcement Network ("FinCEN") to establish and maintain a national registry of corporate beneficial ownership information ("BOI"). The CTA is comprised […]
New Fed Policy on Extend and Hold Bank Loans for Owner-Occupied Real Estate- Welcome Back to 2008
A little over two months ago, the federal banking authorities (Feds) issued a new Policy Statement, a re-vamp and expansion of the 2008 “extend and hold” or “pretend and extend” policy that emerged from the 2008 Bank Liquidity […]
New Fed Policy on Extend and Hold Bank Loans for Construction Loans – Welcome back to 2008
A little over two months ago, the federal banking authorities (Feds) issued a new Policy Statement, a re-vamp and expansion of the 2008 “extend and hold” or “pretend and extend” policy that emerged from the 2008 Bank Liquidity […]
Corporate Transparency Act is Here – What Lawyers Should Know
The Corporate Transparency Act's (CTA) Final Rule has been enacted. Beginning on January 1, 2024, the CTA will be enforceable against all reporting companies, beneficial owners, and applicants. Attorneys, accountants, bankers, and financial consultants […]