HVCRE Exposure for Interim Lender and Third Party Lender Loans

The purpose of this Notice is to provide information regarding High Volatility Commercial Real Estate (HVCRE) Exposure for Interim Lender and Third-Party Lender Loans. On December 13, 2019, the Office of the Comptroller of the Currency, the Federal Reserve Board and the Federal Deposit Insurance Corporation (collectively, the “Agencies”) published a Final Rule regarding Regulatory Capital Treatment for High Volatility Commercial Real Estate (HVCRE) Exposures [84 FR 68019]. The Final Rule is effective April 1, 2020.