The First 100 Days
CREFC's Government Relations Team is closely monitoring key legislative and regulatory developments shaping the commercial real estate finance industry. Explore our First 100 Days: Legislative Update and First 100 Days: Regulatory Update for insights into the evolving policy landscape.
First 100 Days: Legislative Update (1/28/25)
First 100 Days: Regulatory Update (1/28/25)
Election 2024 Outcome Analysis: Implications for CRE and Multifamily Finance
The 2024 election results are in, and CREFC has prepared an in-depth
Election 2024 Outcome Analysis to explore how the outcomes will shape policy in 2025 and beyond. This comprehensive analysis examines key issues in the commercial and multifamily real estate finance industry, providing insights into the potential legislative and regulatory landscape.
While members of CREFC's Government Relations team do not forecast election results, our goal remains to dig deeper into the factors that influence critical areas of legislation and regulation.
Outcome Analysis:
CREFC Election 2024 Outcome Analysis (11/18/24)
Scenario Analyses:
CREFC Election 2024 Scenario Analysis (10/28/24)
CREFC Election 2024 Scenario Analysis (10/22/24)
CREFC Election 2024 Scenario Analysis (10/8/24)
Recent Policy Developments (as of Q3 2024)
Basel Endgame Advocacy
The federal banking regulators plan to repropose the Basel Endgame Capital rules with significant changes. CREFC had submitted comments and coordinated a real estate industry letter on proposed rules and is waiting for the re-proposal to see the extent to which our comments were taken into consideration. CREFC plans to continue advocacy as needed following the release of the re-proposal.
Tax Policy Working Group
Convened a group of member experts on tax to analyze and triage key tax priorities ahead of 2025. With the expiration of key provisions in the 2017 Tax Cuts and Jobs Act, Congress is expected to take up a tax bill next year. CREFC will engage with lawmakers and staff on key tax issues through the end in preparation the tax push early next year.
15c2-11 No Action Letter Expiration
CREFC is engaging with CMBS broker dealers on the upcoming application of 15c2-11 public data requirements for conduit CMBS. While CREFC and other trades successfully exempted 144A bonds from the public disclosure requirements, the public CMBS requirements are scheduled to come online in January 2025. CREFC will follow up with the SEC and/or on Capitol Hill as necessary.
Conflicts of Interest Rule
Successfully advocated for narrowing the overly broad scope of the SEC’s Conflicts of Interest in Securitizations rule to target conflicted transactions and relevant parties more appropriately. CREFC partnered with other organization on an implementation toolkit.