ICBA told regulators it appreciates their swift release of a proposed rule to implement S. 2155 reforms to reporting high-volatility commercial real estate exposures. The proposal would simplify the definition of HVCRE exposures to conform to the statutory definition of HVCRE acquisition, development, or construction loans.
In its comment letter, ICBA questioned whether the punitive treatment of AD&C loans is needed for community banks and recommended removing the elevated risk-weight requirement for banks with total consolidated assets of $50 billion or less.
Read ICBA Comment Letter
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