In late July 2023, US banking agencies released proposals to significantly revise the risk-based regulatory capital requirements for certain midsize and larger US banking organizations. These proposals would have a critical impact on the banking industry, as the amount of capital a bank must maintain with respect to any particular loan, investment or activity is typically a significant—if not the most significant—factor in determining whether an activity is profitable, or even feasible. The proposals are not “capital neutral,” and may increase the capital charge for several aspects of the commercial real estate finance sector.
Please join Mayer Brown partners Eric Reilly, Miller Smith, and Matthew Bisanz for an in-depth discussion of the proposed requirements and what they mean for CRE.
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