- Posts by J. Evan Nogay
AssociateEvan has experience litigating contractual disputes, construction matters, business torts, director and officer liability claims, and class actions and has litigated cases in both state and federal courts across the country ...
With the amount of commercial real estate loans scheduled for maturity over the next several years expected to increase significantly, there is accompanying heightened risk that some borrowers may be unable to replace their maturing debt with new debt under reasonable terms and prevailing market conditions (refinance risk). On October 3, 2024, the Office of the Comptroller of the Currency (“OCC”) issued OCC Bulletin 2024-29, which provides guidance to banks in the management of credit risk associated with refinancing commercial loans. The bulletin, which applies to all banks with commercial loan portfolios, outlines that refinance risk affects both individual loan transactions and loan portfolios and can be driven by both external and borrower-specific factors. The bulletin highlights the need for banks to have related risk management processes that are appropriate for their size, complexity, risk profile and loan types.
About MVA White Collar Defense, Investigations, and Regulatory Advice Blog
As government authorities around the world conduct overlapping investigations and bring parallel proceedings in evolving regulatory environments, companies face challenging regulatory and criminal enforcement dynamics. We help keep our clients up to date in these fast-moving areas and to serve as a thought leader.
The latest from MVA White Collar Defense, Investigations, and Regulatory Advice Blog
- OCC Revises Recovery Planning Guidelines for Large Banks
- OCC Issues Guidance Reminding Banks of Risks Associated with Refinancing Commercial Loans
- CFPB Finalizes Personal Financial Data Rights Rule 1033
- SEC Settlement Reminds Firms to Periodically Review Their Use of Models, Calculators and Tools When Making Client Recommendations