Social Distancing For Distressed Loan Negotiations: The Role Of Reservation Of Rights Letters

In the wake of the global COVID-19 pandemic and the related economic fallout, Borrowers and Lenders have found themselves in a novel and challenging business environment. Commercial mortgage Lenders have been, and will continue to be for the foreseeable future, inundated with loan modification and workout requests from Borrowers who have defaulted under their loans, are facing an imminent Default or just need some “breathing room.” In light of the difficulties facing many commercial […]

By | July 15th, 2020 ||

SIFMA Asks FINRA To Allow Remote Branch Office Inspections

SIFMA requested that FINRA allow member firms to rely on remote inspections of branch offices for the duration of the COVID-19 pandemic.

In a comment letter on FINRA proposed amendment to Rule 3110 (“Supervision”) to temporarily extend the annual office inspection deadline for member firms until March 31, 2021 (see previous coverage), SIFMA asked that FINRA member firms “be permitted to rely on remote branch inspection programs that leverage existing, proven processes and technology to ensure that sales practice risks, […]

By | July 5th, 2020 ||

New York Passes Bill To Increase Transparency In Lending

On July 23, 2020, in an effort to increase transparency in commercial financings so borrowers may make more informed decisions, the New York State legislature passed a bill, S5470B, which currently awaits the Governor’s signature. The bill requires certain commercial financing providers to disclose to recipientsM1 critical information about the amount, pricing, and terms of specific commercial financings, upon making the offers. This information must be disclosed in uniform formatting, to be determined by the New […]

By | June 29th, 2020 ||