MBA Comments on Prudent Commercial Real Estate Loan Accommodations and Workouts
The Mortgage Bankers Association commented on a proposed policy statement on commercial real estate loan accommodation and workouts published by the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corp. and the National Credit Union Administration.
The agencies’ proposal, Docket ID OCC–2022–0017, intends to update the Policy Statement on Prudent Commercial Real Estate Loan Workouts issued by the Federal Financial Institutions Examination Council in 2009, which is useful for the Agencies and financial institutions in properly managing risk in commercial real estate loan workouts.
MBA said in a letter it found the proposal “reasonable in its reaffirmation of key principles from the 2009 Policy Statement on Prudent Commercial Real Estate Loan Workouts as well as its introduction of a new section on short-term loan accommodations, information about changes in accounting principles and revisions and additions to examples of loan workouts.”
MBA noted it will continue to review the concepts in the proposal through the companion proposal released by the Federal Reserve Board of Governors on September 15.
Contact MBA Associate Vice President of Multifamily/Commercial Policy Stephanie Milner with any questions or comments about the proposal.
