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News

NCREIF and CREFC Release Fourth Quarter 2024 Debt Fund Aggregate Report

April 17, 2025

We are pleased to provide you with the NCREIF/CREFC Open-End Debt Fund Aggregate Report for Fourth Quarter 2024. The full Membership Report is located in the CREFC Resource Center for CREFC Members only. This Snapshot Report is available to the public and also can be found on the CREFC website.

For any questions or suggestions and/or if you wish to become a debt fund contributor to the Aggregate, please contact Lisa Pendergast.


The NCREIF/CREFC Open-End Debt Fund Aggregate 
 
The NCREIF/CREFC Open-End Debt Fund Aggregate is a fund-level aggregate comprising open-end funds that provide credit and financing to commercial real estate owners. This report will be issued in a draft “consultation” format for at least one year to obtain the appropriate level of industry feedback before it is rolled out as an official NCREIF/CREFC product. 
 
About the NCREIF/CREFC Open-End Debt Fund Aggregate

  • Is a project by the industry for the industry that has been in the works for several years with input from NCREIF, CREFC and its members, and data contributing managers, investors, and consultants. 
  • Is anticipated to be published quarterly. Results will never reveal individual fund performance. 
  • Is NOT a BENCHMARK, yet, but is a major step toward the goal of creating a more focused index/benchmark of funds that meets certain investment inclusion criteria (which are to be determined)
  • Will enhance investors’ interest and understanding of the rewards and risks of private real estate debt funds, which may lead to increased allocations to debt, benefiting managers, investors, and commercial real estate finance industry professionals. 
  • Contains funds with various strategies and styles ranging from core to value-add, as reported by the managers. The performance metric is a time-weighted return. The returns are equally weighted across the funds since the aggregate contains a few large funds that would dominate the results if it they were value weighted. 

Aggregate Furthers CREFC’s and NCREIF’s Missions

About CREFC

  • CREFC is the trade association for the commercial real estate finance industry. Member firms include balance sheet and securitized lenders, loan and bond investors, private equity firms, servicers and rating agencies, among others. 
  • Our industry plays a critical role in the financing of office buildings, industrial and warehouse properties, multifamily housing, retail facilities, hotels, and other types of commercial real estate that help form the backbone of the American economy.
  • CREFC promotes liquidity, transparency, and efficiency in the commercial real estate finance markets. It does this by acting as a legislative and regulatory advocate for the industry, serving a vital role in setting market standards and best practices, providing education for market participants, and publishing the well tracked CREFC Board of Governors Sentiment Index. Our most recent collaborative effort is working with our friends at NCREIF to develop the NCREIF/CREFC Open End Debt Fund Aggregate.
  • CREFC hosts major industry conferences that bring together market participants from leading commercial real estate finance companies and organizations. Complementing these major conferences are regular After-Work Seminars and regional conferences held throughout the year on an annual basis

About NCREIF

  • NCREIF is the leading provider of investment performance indices and transparent data for US commercial properties. Data Contributor Members submit data to NCREIF for inclusion in its various indices and data products. NCREIF is a member-driven, not-for-profit association that improves private real estate investment industry knowledge by providing transparent and consistent data, performance measurement, analytics, standards, and education.
  • NCREIF serves the institutional real estate investment community as a non-partisan collector, validator, aggregator, converter and disseminator of commercial real estate performance and benchmarking information. Our members include investment managers, investors, consultants, appraisers, academics, researchers and other professionals in the real estate investment management industry.
  • NCREIF is a data service provider that meets its members' and the investment and academic community's need for high quality, transparent, timely and accurate commercial real estate data, performance measurement and benchmarking indices, investment analysis, reporting standards, research, education and peer group interaction 
NCREIF Debt Fund Aggregate Fund Inclusion

Investment Managers must:

  • Offer an open-end debt fund product to institutional investors that includes predominantly private U.S. commercial and multifamily real estate debt. Specifically, 80% of total assets must be invested in private commercial and multifamily debt real estate.
  • Calculate quarterly net asset values and returns on a market-value basis.
  • Agree to submit all requested data and do so within the time frame required.

Funds included have different: 

  • Structures, strategies, liquidity provisions, dividends, accounting, and valuation policies, all of which affect performance and comparability. As a result, this product is not a benchmark.  

Contact  

Lisa Pendergast
President & CEO
646.884.7570
lpendergast@crefc.org
The information provided herein is general in nature and for educational purposes only. CRE Finance Council makes no representations as to the accuracy, completeness, timeliness, validity, usefulness, or suitability of the information provided. The information should not be relied upon or interpreted as legal, financial, tax, accounting, investment, commercial or other advice, and CRE Finance Council disclaims all liability for any such reliance. © 2025 CRE Finance Council. All rights reserved.
NCREIF and CREFC Release Fourth Quarter 2024 Debt Fund Aggregate Report
April 17, 2025
We are pleased to provide you with the NCREIF/CREFC Open-End Debt Fund Aggregate Report for Fourth Quarter 2024.

News

First 100 Days: Regulatory Update

April 15, 2025

President Donald Trump issued a Presidential Memo (Directing the Repeal of Unlawful Regulations) on April 9, allowing agency heads to “finalize rules without notice and comment, where doing so is consistent with the ‘good cause’ exception in the Administrative Procedure Act.” 

As reported by Politico, this action accelerates the White House’s efforts “to dismantle the federal regulatory machine, although Trump’s directive to skip the notice-and-comment process will likely face legal challenges.”

  • The memo seems to assume that the 2024 Loper Bright ruling applies retroactively, although as reported in previous CREFC Policy and Capital Markets Briefings, the Supreme Court explicitly stated that the decision was forward-looking.
  • Loper Bright overturned what had been known as the “Chevron Doctrine,” which directed courts to defer to agency interpretations of ambiguous federal laws and regulations.

What they're saying: Treasury Secretary Scott Bessent, in a speech to the American Bankers Association on the same day as the issuance of the the memo, said that the Treasury now “intends to play a greater role in bank regulation” and ensure “that the financial services regulators fulfill their statutory mandates consistent with [Trump’s] priorities.”

Bessent also stressed the need to modernize the bank capital regime. Arguing that the Biden-era proposed Basel Endgame was not the right starting point for this modernization effort, Bessent stated:

We should not outsource decision making for the United States to international bodies. Instead, we should conduct our own analysis from the ground up to determine a regulatory framework that is in the interests of the United States. To the extent that the Endgame standards can provide inspiration, we could borrow selectively from them. But this should only be done to the extent that we can independently validate the underlying rationale and then make that rationale available for public comment.
Confirmation Process for Senior Regulators Continues

  • Former Securities and Exchange Commissioner (SEC) Paul Atkins was confirmed as the agency’s new Chair on April 9. 
  • According to Politico, Atkins is considered the “intellectual godfather of Republican market regulation” and will seek to usher in a “sweeping age of deregulation.” He is expected to make it easier for companies to go public in the U.S., pull back on enforcement, and develop new rules for digital assets.
  • Yes, but: The SEC has lost a lot of staff, including hundreds of whom took a $50,000 offer to voluntarily leave the agency. A former SEC official told Politico:
If he’s going to accomplish what he wants, whether it’s regulation or deregulation, he’s gonna need expert, experienced staff. And the agency is actively suffering from the largest loss of talent in its history. It won’t be easy.

  • Please see recent CREFC Policy and Capital Markets Briefings for more color on Atkins.
On April 10, the Senate Banking Committee held a hearing to consider Federal Reserve Governor Michelle Bowman’s nomination to serve as Vice Chair for Supervision. Bowman highlighted her commitment to regulatory pragmatism, advocating for tailored regulations, enhanced regulatory transparency, and innovation in the banking system.

  • Democrats questioned Bowman about President Trump’s tariff policies and the Fed’s independence, raising concerns about the Fed’s ability to counter potential risks to financial stability. 
  • Republicans focused their questions on easing regulatory burdens and the Fed’s shortcomings leading up to the March 2023 bank failures.
Go deeper: Bowman committed to maintaining the Fed’s independence, but declined to answer how she would respond if the Office of Management and Budget (OMB) required the Fed to submit its rules for White House review prior to publication. 
 
  • She stated that such a request would not necessarily infringe on the Fed’s independence and emphasized her support of providing a cost-benefit analysis to justify the agency’s rulemakings. 
What about Basel: Bowman said that the Fed needs to “take a fresh look” at the latest Basel agreement to see what’s appropriate for U.S. banks and their ability to be privy to a level playing field internationally.
 
  • Bowman’s remarks echoed similar themes shared by Treasury Secretary Scott Bessent earlier in the week. 
CREFC will continue to update its membership on key regulatory developments, both in the first 100 days and beyond. Please see here for our Regulatory Tracker.
 
Please contact Sairah Burki (sburki@crefc.org) with any questions.

Contact 

Sairah Burki
Managing Director,
Head of Regulatory Affairs and Sustainability
703.201.4294
sburki@crefc.org
The information provided herein is general in nature and for educational purposes only. CRE Finance Council makes no representations as to the accuracy, completeness, timeliness, validity, usefulness, or suitability of the information provided. The information should not be relied upon or interpreted as legal, financial, tax, accounting, investment, commercial or other advice, and CRE Finance Council disclaims all liability for any such reliance. © 2025 CRE Finance Council. All rights reserved.
First 100 Days: Regulatory Update
April 15, 2025
President Donald Trump issued a Presidential Memo (Directing the Repeal of Unlawful Regulations) on April 9, allowing agency heads to “finalize rules without notice and comment.."

News

Capital Markets Update Week of 4/15

April 15, 2025

Private-Label CMBS and CRE CLOs

Three transactions totaling $930 million priced last week:

  • WFCM 2025-DWHP, a $330 million SASB backed by a floating-rate, five-year loan (at full extension) for Driftwood Capital to refinance nine hotels totaling 1,866 rooms in five states.
  • SDAL 2025-DAL, a $330 million SASB backed by a floating-rate, five-year loan (at full extension) for Elliott Management and Chartres Lodging Group to refinance the Sheraton Dallas hotel in downtown Dallas.
  • BWAY 2025-1535, a $300 million SASB backed by a fixed-rate, five-year loan for Vornado Realty Trust to refinance a 106,481 sf purpose-built retail and theater condominium located in Times Square.

According to Commercial Mortgage Alert, prior to the above noted transactions, no new CMBS have hit the market since President Trump’s April 2 tariff announcement. The three transactions priced last week had been in mid-marketing when tariffs were first announced. According to CMA, “All printed at much wider-than-expected spreads.”

Issuance by the numbers: Year-to-date private-label CMBS and CRE CLO issuance totals $47.4 billion, a 126% increase from the $21 billion recorded for same-period 2024. 

Spreads Trend Wider

  • Conduit AAA and A-S spreads were unchanged at +108 and +150. YTD, they have widened 33 bps and 45 bps, respectively.
  • Conduit AA spreads were unchanged at +220, while A spreads widened 25 bps to +275. YTD, they are wider by 130 bps and 160 bps, respectively.
  • Conduit BBB- spreads widened 50 bps to +625. YTD, they are wider by 200 bps.
  • SASB AAA spreads widened 20-23 bps to the +160 to +178 range, depending on property type. YTD, they have widened 53 to 68 bps.
  • CRE CLO AAA spreads widened 30 bps/25 bps (Static/Managed) to +180/+180, while BBB- spreads widened 105 bps/90 bps to +475/+475.

Agency CMBS

  • Agency issuance totaled $2.8 billion last week, comprising $1.3 billion of Freddie K and Multi-PC transactions, $1.3 billion of Fannie DUS, and $153.3 million of Ginnie Mae Project Loan transactions.
  • Agency issuance for the year totals $37.1 billion, 34% higher than the $27.6 billion for same-period 2024.

The Economy, the Fed, and Rates…

Economic Data and Outlook

  • Inflation Cooled Pre-Tariff, but the Future Looks Hotter: March CPI and PPI data showed unexpected cooling, with headline CPI falling 0.05% month-over-month and PPI dropping 0.4%, largely due to lower energy costs. Core CPI rose just 0.06%. However, this data precedes the full impact of recent tariff hikes. Economists widely expect tariffs to push inflation higher later this year; New York Fed President John Williams projected inflation could reach 3.5% to 4%. The timing remains uncertain, potentially delayed until June or later, as businesses likely stockpiled inventory (estimated at a two-month cushion) ahead of the tariffs. 
  • Signs of Consumer Strain Emerge: While some bank executives maintain that consumers remain resilient, warning signs are flashing. JPMorgan reported credit card loan charge-offs hitting a 13-year high in Q1, surpassing pre-pandemic levels. Philadelphia Fed data showed the share of borrowers making only minimum payments reached a 12-year high at the end of 2024, with delinquencies also rising.
Moreover, the University of Michigan Consumer Sentiment Index plunged in April to a roughly three-year low, citing "growing worries about trade war developments." Expectations for unemployment rose to the highest since 2009, and inflation expectations surged to multi-decade highs. Retail foot traffic data suggest a shift toward low-priced warehouse stores, possibly indicating stockpiling ahead of tariffs. JPMorgan CEO Jamie Dimon noted credit quality hinges on employment, currently at 4.2%.

  • Growth Forecasts Dimmed, Recession Fears Rise: Economists anticipate a significant economic slowdown due to tariffs and related uncertainty. NY Fed's Williams expects GDP growth below 1% this year. JPMorgan pegs recession odds at 50/50, while BlackRock's Larry Fink stated the U.S. is "very close, if not in a recession now." Several economists forecast a recession as their base case if high tariffs persist. Goldman Sachs expects only 0.5% GDP growth this year.
  • Fiscal Concerns Loom: The U.S. fiscal deficit reached $1.307 trillion in the first half of fiscal 2025 (October-March), the second-largest on record for that period, partly driven by record interest payments on the national debt totaling $582 billion. Economists noted the link between large budget deficits and trade deficits, highlighting a contradiction in pursuing policies aimed at lowering the trade deficit, while potentially increasing the budget deficit (e.g., via tax cuts funded by uncertain tariff revenue).
  • Oil Market Impact: The U.S. shale revolution significantly reduced the U.S. trade deficit by turning the nation into a net oil exporter. However, current administration policies, including pressure on OPEC+ and the potential economic slowdown from tariffs, have pushed WTI crude prices towards $60/barrel. Analysts warn that prices below the average breakeven point for shale producers (estimated around $65/barrel) could curtail U.S. production, necessitate increased imports, and consequently widen the trade deficit again, undermining a key administration goal.
Federal Reserve Policy
 
  • Patient Stance Amid Uncertainty: Fed officials signaled a clear intention to remain patient and hold interest rates steady, ruling out preemptive "insurance" cuts against a potential tariff-induced slowdown. Chair Powell emphasized no need to hurry policy moves, while others like Cleveland Fed President Hammack stressed the importance of waiting to "move in the right direction." NY Fed President Williams called the current stance "entirely appropriate."
  • Navigating a Policy Dilemma: Officials acknowledged the conflicting pressures created by tariffs: rising inflation calls for tighter policy, while potential weakening growth and higher unemployment call for easing. Minneapolis Fed President Kashkari noted the "hurdle to change the federal funds rate one way or the other has increased due to tariffs." St. Louis Fed President Musalem highlighted the "distinct possibility" of rising inflation alongside a softening labor market. Lawrence Summers described the situation as "standard emerging-market territory where a central bank is hamstrung."
  • Market Intervention Readiness: While bank executives suggested regulatory tweaks to aid market functioning, Fed officials like Boston Fed President Collins and Kashkari stated that while markets show stress, they are functioning adequately without liquidity concerns overall. However, Collins affirmed the Fed "would absolutely be prepared" to use its tools to intervene and stabilize markets if conditions became disorderly.
  • Rate Cut Outlook Dims: While futures markets still price in rate cuts this year, Fed commentary suggests a higher bar for easing. Several officials emphasized the need for more data and clarity on the economic trajectory before adjusting policy. Some economists now forecast only one rate cut late in the year, likely December.
Markets
 
  • ‘Not Normal’ Yield Surge: U.S. Treasury yields experienced unusually sharp increases despite broader market turmoil. The 10-year Treasury yield surged approximately 50 basis points over the week to end near 4.5%, its largest weekly rise since 2001. The 30-year yield jumped over 48 basis points to near 4.9%, its biggest weekly increase since 1987. This counterintuitive move, yields rising when haven demand should push them lower, was described by analysts as "not normal behavior."
  • Market Stability Questions: The erratic yield movements and signs of stress raised concerns about the stability and liquidity of the Treasury market, drawing comparisons to the pandemic-induced seizure in March 2020. Speculation centered on potential causes, including foreign capital flight driven by tariff policies and eroding confidence in U.S. assets, as well as the possible unwinding of leveraged hedge fund strategies like the Treasury basis trade.
  • Extreme Volatility, Weekly Gain: The S&P 500 experienced extreme volatility, including sharp declines and powerful rallies, ultimately notching its best weekly gain (+3.8%) since November 2023. However, the intra-week trading range rivaled the depths of the pandemic, described as a "roller coaster" driven by "emotionally charged" sentiment and tariff uncertainty. The VIX volatility index rose to levels last seen in March 2020.
  • Dollar Weakens Despite Risk-Off: The dollar fell sharply against major currencies, hitting a three-year low against the euro, contrary to its typical behavior of strengthening during global financial stress. This simultaneous decline in stocks and bonds fueled concerns about waning confidence in U.S. assets.
  • Haven Status Questioned: Fund managers warned that erratic policymaking, rising trade barriers, and threats to institutional stability (like Fed independence) are undermining the dollar's long-standing role as the world's primary safe haven and reserve currency. Bob Michele of JPMorgan Asset Management stated, "There is [now] a very good case for the end of American dollar exceptionalism." This potential shift could lead to higher U.S. borrowing costs and diminished global influence over time.
  • Gold Surges to Record Highs: Gold benefited significantly from the market turmoil, climbing over 6.5% to a record high of $3,237 per troy ounce, its largest weekly gain since the early pandemic stages in March 2020. Investors flocked to gold as confidence in traditional havens like U.S. Treasuries and the dollar wavered amid the tariff fallout. Analysts noted gold buying was motivated by fear and worries "about the system breaking."
You can download CREFC’s one-page MarketMetrics, which includes statistics covering the economy and the CRE debt capital markets, here
Contact Raj Aidasani (raidasani@crefc.org) with any questions.

 

Contact 

Raj Aidasani
Managing Director, Research
646.884.7566
The information provided herein is general in nature and for educational purposes only. CRE Finance Council makes no representations as to the accuracy, completeness, timeliness, validity, usefulness, or suitability of the information provided. The information should not be relied upon or interpreted as legal, financial, tax, accounting, investment, commercial or other advice, and CRE Finance Council disclaims all liability for any such reliance. © 2025 CRE Finance Council. All rights reserved.
Capital Markets Update Week of 4/15
April 15, 2025
Three transactions totaling $930 million priced last week.

News

Department of Government Efficiency Progress and Future under Musk

April 15, 2025

In early 2025, the Trump administration launched the Department of Government Efficiency (DOGE) with the stated goal of reducing federal bureaucracy and improving operational efficiency across government agencies. The effort is scheduled to wrap up by July 4, 2026, and set an ambitious goal of saving $2 trillion. 

Why it matters: DOGE is an initiative to streamlining federal operations and reducing government expenditures; rather than functioning as a standalone agency, DOGE operates by embedding specialized teams within existing federal agencies

  • Integration into existing agencies: DOGE deploys four-member teams—typically comprising a team lead, an engineer, a human resources specialist, and an attorney—into various federal agencies
  • Leadership and oversight: Tech entrepreneur Elon Musk was appointed to lead DOGE as a special adviser to President Trump; under his direction, DOGE has been granted authority to audit, restructure, and intervene in agency operations. Officially, Amy Gleason serves as the acting administrator, though Musk is the de facto head. 
  • Mandate and objectives: DOGE aims to "modernize Federal technology and software" for greater efficiency; this includes digitization, workforce optimization, and technology-driven service improvements.
By the numbers: Since its inception, DOGE has made sweeping changes across a variety of agencies.
 
  • Automation tools and algorithm-driven assessments were used to identify redundancies and consolidate roles, which has led to substantial backlash from employee unions, watchdog organizations, and members of Congress.
  • Thousands of federal employees—many probationary without civil service protections—have been laid off. The legality of these layoffs remains in limbo amid various court challenges. Agencies have also been directed to submit plans for a broader reduction in force. 
  • On its website, DOGE claims to have saved $150 billion already, including 676 lease terminations totaling ~$400M in savings. The total has been subject to debate, and Musk himself has speculated the cuts may not reach the $2 trillion goal.

Yes, but: The initiative has also faced internal friction. 

The future of DOGE remains unclear: It is uncertain whether the department will continue under new leadership after a Musk departure or undergo restructuring. 

Contact James Montfort (jmontfort@crefc.org) with any questions.

Contact  

James Montfort
Manager,
Government Relations
202.448.0857
jmontfort@crefc.org
The Department of Government Efficiency (DOGE) acronym references a popular meme featuring a dog. The meme has also been leveraged as a cryptocurrency.
The information provided herein is general in nature and for educational purposes only. CRE Finance Council makes no representations as to the accuracy, completeness, timeliness, validity, usefulness, or suitability of the information provided. The information should not be relied upon or interpreted as legal, financial, tax, accounting, investment, commercial or other advice, and CRE Finance Council disclaims all liability for any such reliance. © 2025 CRE Finance Council. All rights reserved.
Department of Government Efficiency Progress and Future under Musk
April 15, 2025
In early 2025, the Trump administration launched the Department of Government Efficiency (DOGE) with the stated goal of reducing federal bureaucracy and improving operational efficiency across government agencies.

News

Forums Update: Issuers Spotlight

April 15, 2025

Brigid Mattingly (Chair), Shaishav Agarwal (Chair-Elect) and Jane Lam (Past-Chair) form the Issuer Forum’s “Leadership Working Group,” which sets agendas and priorities for the Forum and represents this constituency on CREFC’s Policy Committee.

Why it matters: Each Forum interacts with Issuer Forum members to address issues critical to their business sector and works to achieve solutions that serve a common purpose. CREFC works closely with Forum leaders and members to:

  • Ensure all voices are heard,
  • Assist in finding consensus amidst disparate and converging views,
  • Share those views when appropriate with regulators and legislators, working alongside CREFC’s experienced Government Relations Team, and
  • Develop new best practices and monitor existing ones.
Key Focus Areas for Issuers include:
  • Market volatility tied to tariff announcements and geopolitical instability.
  • Preparing for continued volume in CMBS issuance, particularly in floating-rate single-asset/single-borrower (SASB) transactions.
  • Challenges in securitizing pari-passu pieces considering conduit transaction sizes and the execution timing on conduit transactions.
  • Managing office maturities in 2025 and the bifurcation between Class-A and Class-B properties and below.
  • Value of cash-management structures in conduit lending and alternate credit enhancements.
Looking ahead: Leaders are concerned about the potential negative impacts of financial market volatility and the current macro environment as both could create challenges in the execution of new-issue conduit and SASB transactions. The Forum remains focused on sourcing loans and bringing securitizations to market, while bridging the needs of borrowers and investors.

Key Policy Issues:

  • 2025 Tax Legislation: The new administration has begun work on reauthorizing the 2017 Tax Cuts and Jobs Act and is considering a number of tax issues impacting businesses and individuals.
  • Rule 15c2-11 Public Disclosure of 144A Bonds: The SEC previously issued an order exempting 144A fixed-income securities from SEC 15c2-11 disclosure. CREFC and its members urged the SEC and Congress to take action to prevent the application of 15c2-11 to fixed-income securities. On November 22, 2024, the SEC issued a ‘No Action’ letter, with no expiration date, that exempts fixed-income securities from the disclosures. The exemption order was a major win for the industry.
What’s Next?
 
  • Forum leaders will present an update on their Forum at CREFC’s Annual Conference in New York (June 9-11, 2025).
  • Also at the June Annual Conference, the chairs will welcome the next Chair-Elect to join their leadership slate.
To join the Issuers Forum, please register here.

For any forum related questions, please contact Rohit Narayanan (RNarayanan@crefc.org).

Contact  

Rohit Narayanan
Managing Director,
Industry Initiatives
646.884.7569
rnarayanan@crefc.org
Spring 2025
The information provided herein is general in nature and for educational purposes only. CRE Finance Council makes no representations as to the accuracy, completeness, timeliness, validity, usefulness, or suitability of the information provided. The information should not be relied upon or interpreted as legal, financial, tax, accounting, investment, commercial or other advice, and CRE Finance Council disclaims all liability for any such reliance. © 2025 CRE Finance Council. All rights reserved.
Forums Update: Issuers Spotlight
April 15, 2025
Brigid Mattingly (Chair), Shaishav Agarwal (Chair-Elect) and Jane Lam (Past-Chair) form the Issuer Forum’s “Leadership Working Group,” which sets agendas and priorities for the Forum and represents this constituency on CREFC’s Policy Committee.

News

House Passes Senate Reconciliation Bill to Tee Up Tax Legislation

April 15, 2025

On April 10, the House of Representatives advanced the Senate’s budget framework (click here for our previous coverage) to officially begin legislative work on President Donald Trump’s “big, beautiful bill.”

Why it matters: The reconciliation bill will include 

  • Tax provisions,
  • New spending on defense, energy, immigration; 
  • Spending cuts, and
  • Raising the debt ceiling by $5 trillion. 

What they’re saying: House GOP leaders had originally intended to vote on the bill Wednesday, but deficit hawks and the House Freedom Caucus holdouts were threatening to vote against the resolution due to concerns the Senate language did not guarantee enough spending cuts.  

  • The budget resolution passed 216 to 214 with two Republicans—Thomas Massie (R-KY) and Victoria Spartz (R-IN) — joining Democrats in voting against the measure. 
  • President Trump, Speaker Mike Johnson (R-LA), and Senate Majority Leader John Thune (R-SD) met with holdouts to assure them of the leadership’s commitment to cut spending. The Senate version only mandated $4 billion in cuts whereas the original House bill had $1.5 trillion in cuts. 
  • Speaker Johnson also promised House Budget Chairman Jodey Arrington (R-TX) that the final bill would not raise the deficit. Both understood that promise could be fulfilled by counting additional revenue through economic growth, rather than just spending cuts.  
Yes, but: The budget resolution is the easy part for congressional leaders. Now, lawmakers will have to fill in the blanks on tax policy and any spending cuts, and the thin margins have proven difficult to navigate. 
 
  • Republicans can only lose four GOP senators in the 53 to 47 chamber. 
  • Sen. Rand Paul (R-KY) opposes the bill because it raises the debt ceiling. 
  • At least three GOP senators — Susan Collins (R-ME), Josh Hawley (R-MO), and Lisa Murkowski (R-AK) — are strongly opposed to Medicaid cuts. Democrats have pointed to the House budget as an attempt to slash at least $800 billion from the program. 
  • Four Republican senators — Lisa Murkowski (R-AK), John Curtis (R-UT), Thom Tillis (R-NC), and Jerry Moran (R-KS) — stressed the importance of maintaining a stable and predictable tax framework to promote domestic energy development. 
    • In a letter to Leader Thune last week, the four senators urged leaders to consider Inflation Reduction Act (IRA) tax credits on their merits rather than indiscriminately slashing them. 
It will be difficult to cobble together $1.5 to $2 trillion in spending cuts without touching entitlement programs like Medicaid or popular programs like defense. At the end of the day, House spending hardliners may be faced with a choice: block President Trump’s first major legislative victory or swallow fewer spending cuts. 

The bottom line: Congressional GOP leaders hope to wrap up the reconciliation bill by Memorial Day 2025, though Treasury Secretary Scott Bessent is hopeful that it could be completed by summer. As lawmakers begin to add detail to the policy, political horse-trading and redlines will chart a narrow path to enactment. 

Contact David McCarthy (dmccarthy@crefc.org) with any questions. 

Contact 

David McCarthy
Managing Director,
Chief Lobbyist, Head of Legislative Affairs
202.448.0855
dmccarthy@crefc.org
The information provided herein is general in nature and for educational purposes only. CRE Finance Council makes no representations as to the accuracy, completeness, timeliness, validity, usefulness, or suitability of the information provided. The information should not be relied upon or interpreted as legal, financial, tax, accounting, investment, commercial or other advice, and CRE Finance Council disclaims all liability for any such reliance. © 2025 CRE Finance Council. All rights reserved.
House Passes Senate Reconciliation Bill to Tee Up Tax Legislation
April 15, 2025
On April 10, the House of Representatives advanced the Senate’s budget framework to officially begin legislative work on President Donald Trump’s “big, beautiful bill.”

News

Go Deeper: Potential Tax Provisions in Focus

April 15, 2025

With the reconciliation process full steam ahead (as described in the story above), we will begin to see specific tax policy provisions introduced by lawmakers in the coming weeks.

Key provisions believed to be in contention are described below.

Reauthorize Expiring TCJA provisions: The Senate is counting this as budget neutral rather than a roughly $4 trillion cost, though the parliamentarian or House deficit hawks could balk and trigger a stalemate.

Fix the SALT Cap: The TCJA capped the federal deduction for state and local tax (SALT) at $10,000 per filer, even for joint returns. 

  • The GOP SALT caucus has been effective in winning over President Donald Trump and leadership in advocating to raise the $10,000 cap. 
  • The exact number is to be determined, but insiders are estimating a $25,000 to $50,000 range.
Trump Priorities: No tax on tips, overtime, and Social Security are in the works, though the tips and overtime may prove tricky to implement. The Social Security tax relief could also fall by the wayside if it proves too expensive. 

New Taxes: The reconciliation instructions allow for $1.5 trillion in tax cuts unless they are offset. The Trump priorities and SALT cap could eat into that $1.5 trillion, so lawmakers may be forced to find new revenue. Some potential new taxes cropping up in conversations include:
 
  • Business SALT provisions could limit or eliminate deductions on state and local income or property taxes for businesses, including passthroughs. No details have emerged on what specific form any Business SALT provision might take. 
  • Raising the top individual income tax rate to 39.6% from the current 37%.
  • Taxing large university endowments.
Carried Interest: President Trump has put eliminating capital gains treatment for carried interest income back on the table earlier this year. 

  • While carried interest has key defenders in Congress, it is not clear if those supporters will risk the White House’s ire in preserving it. That said, the provision itself may not be a key priority for Trump.
  • Eliminating carried interest treatment is projected to raise only $13 billion over 10 years, thus tax writers are not looking at it as a major “pay-for” in offsetting new tax cuts. 
Contact David McCarthy (dmccarthy@crefc.org) with any questions.
 

Contact 

David McCarthy
Managing Director,
Chief Lobbyist, Head of Legislative Affairs
202.448.0855
dmccarthy@crefc.org
The information provided herein is general in nature and for educational purposes only. CRE Finance Council makes no representations as to the accuracy, completeness, timeliness, validity, usefulness, or suitability of the information provided. The information should not be relied upon or interpreted as legal, financial, tax, accounting, investment, commercial or other advice, and CRE Finance Council disclaims all liability for any such reliance. © 2025 CRE Finance Council. All rights reserved.
Go Deeper: Potential Tax Provisions in Focus
April 15, 2025
With the reconciliation process full steam ahead (as described in the story above), we will begin to see specific tax policy provisions introduced by lawmakers in the coming weeks.

News

UNC Kenan-Flagler Business School Wins 4th Annual CREFC Real Estate Debt Case Competition  

April 11, 2025

Undergraduate and Graduate Students Compete for $45,000 in Prize Money 
  
NEW YORK, April 11, 2025
– The CRE Finance Council (CREFC), the trade association that exclusively represents the nearly $6 trillion commercial and multifamily real estate finance industry, hosted its 4th Annual Real Estate Debt Case Competition in New York City this week. The event attracted graduate and undergraduate students from 10 U.S. universities with top-rated real estate programs.

Students with a focus on commercial real estate finance participated in this invitation-only competition and competed for a total of $45,000 in prize money.
  
Winners of the 4th Annual Debt Case Competition are: 

  • 1st place - UNC Kenan-Flagler Business School 
  • 2nd place - University of Wisconsin – Madison School of Business
  • 3rd place - Cornell University 

“Now in its fourth year, the CREFC Real Estate Debt Case Study Competition brings together talented graduate and undergraduate students with a deep commitment to commercial real estate finance. We want to thank the student teams participating this year and the senior members of CREFC who served as the competition’s judges. These senior industry professionals offered their valuable expertise in guiding our up-and-coming CRE finance professionals,” said Lisa Pendergast, President and CEO, CREFC. 

“We also want to thank Ares Management LLC for their work in developing a debt case that served as the framework for our competition.”
  
The 10 U.S. universities with top-rated real estate programs invited to participate in this competition include:

  • Columbia University
  • Cornell University
  • Florida State University
  • NYU Schack Institute of Real Estate
  • UNC Kenan-Flagler Business School
  • University of Chicago Booth School of Business
  • University of Florida
  • University of Wisconsin – Madison School of Business
  • UT Austin McCombs School of Business
  • Wharton School of the University of Pennsylvania
Competitors presented their analyses of a CRE lending decision using a case study based on a real-world transaction. The teams were given one week to prepare their analyses and presentations. At the competition, each team presented to a panel of senior CRE executives who served as judges. Teams were appraised on their overall analysis, conclusion, and presentation skills. Winners from a preliminary round advanced to compete in the final round.
  
The competition supports CREFC’s educational objectives to provide meaningful programming and networking opportunities to students and young professionals. CREFC’s Annual Real Estate Debt Case Competition also helps raise the profile of CRE finance among top universities and their students.
  
For additional information on the Real Estate Debt Case Competition or the CREFC Young Professionals Network, please contact Danielle Nathan.
  
About CREFC
The CRE Finance Council (CREFC) is the trade association for the nearly $6 trillion commercial real estate finance industry with a membership that includes approximately 400 companies and 19,000 individuals. Member firms include balance sheet and securitized lenders, loan and bond investors, private equity firms, servicers, rating agencies, and borrowers. For more than 30 years, CREFC has promoted liquidity, transparency, and efficiency in the commercial real estate finance markets. We function as an important legislative and regulatory advocate for the industry, play a vital role in setting market standards and best practices, and provide education for market participants.
  
Contact:
Aleksandrs Rozens
arozens@crefc.org
646-884-7567
 

Contact 

Aleksandrs Rozens
Senior Director,
Communications
646.884.7567
arozens@crefc.org
The information provided herein is general in nature and for educational purposes only. CRE Finance Council makes no representations as to the accuracy, completeness, timeliness, validity, usefulness, or suitability of the information provided. The information should not be relied upon or interpreted as legal, financial, tax, accounting, investment, commercial or other advice, and CRE Finance Council disclaims all liability for any such reliance. © 2025 CRE Finance Council. All rights reserved.
UNC Kenan-Flagler Business School Wins 4th Annual CREFC Real Estate Debt Case Competition
April 11, 2025
The CRE Finance Council hosted its 4th Annual Real Estate Debt Case Competition in New York City this week.

News

CFPB to Revisit Small Business Data Rule

April 8, 2025

In light of ongoing legal challenges, the Consumer Financial Protection Bureau (CFPB) said on April 3 that it will reissue the Dodd-Frank-mandated 1071 requirements regarding data that lenders must collect and report on small-business loans.

Why it matters: The rule was set to phase in compliance starting this summer, but the CFPB action likely will delay implementation while the rule is changed.

  • Separately, the House Financial Services Committee advanced H.R. 976, a bill to repeal the Dodd-Frank requirement mandating data collection. 
  • The bill authored by Rep. Roger Williams (R-TX) passed out of committee on a party-line vote 27-22. While the bill could advance to the House floor, the legislation is unlikely to garner 60 votes to pass the Senate. 

As reported by American Banker, the CFPB, in a legal filing in Revenue Based Finance Coalition v. CFPB, stated: 

CFPB's new leadership has directed staff to initiate a new Section 1071 rulemaking. The CFPB anticipates issuing a Notice of Proposed Rulemaking as expeditiously as reasonably possible. Because the anticipated rulemaking process may be moot or otherwise resolve this litigation, holding this matter in abeyance would conserve the Court's resources.
Background: The CFPB rule, effective as of August 2023, requires small-business lenders to collect data on the race, ethnicity, gender and sexual orientation of those who apply for small business loans. The stated goal was to monitor the accessibility of small business loans and fight discrimination under federal fair lending laws. 

Why it matters to CRE: The CFPB did not exempt commercial real estate mortgages from the final rule.

However, several factors would likely have limited the impact to CREFC members.

  • The small business threshold generally impacted a business with under $5 million in gross annual revenue.
  • Affiliate revenue counted in determining if the borrower is a small business. If the legal borrower was a special purpose entity, the owners or affiliate revenue could have proven that it was not a small business.
  • A lender must have made 100 loans to small businesses in each of the preceding two years to be required to report. For CREFC members, that means 100 loans made to borrowers with under $5 million in gross annual revenue (including affiliates). But the threshold is institution-wide, not limited to a particular business line.
  • Multifamily loans were excluded from 1071 reporting since they are already accounted for in the Home Mortgage Disclosure Act (HMDA) reporting.
Yes, but: Financial institutions with a dedicated small business lending platform would likely have been impacted. Therefore, they would have had to report data on their CRE loans to small businesses, even if that business line had not made 100 CRE loans. 
 
CREFC will continue to monitor 1071-related developments.

Contact David McCarthy (dmccarthy@crefc.org) and Sairah Burki (sburki@crefc.org) with any questions.
 

Contact 

Sairah Burki
Managing Director,
Head of Regulatory Affairs and Sustainability
703.201.4294
sburki@crefc.org

David McCarthy
Managing Director,
Chief Lobbyist, Head of Legislative Affairs
202.448.0855
dmccarthy@crefc.org
The information provided herein is general in nature and for educational purposes only. CRE Finance Council makes no representations as to the accuracy, completeness, timeliness, validity, usefulness, or suitability of the information provided. The information should not be relied upon or interpreted as legal, financial, tax, accounting, investment, commercial or other advice, and CRE Finance Council disclaims all liability for any such reliance. © 2025 CRE Finance Council. All rights reserved.
CFPB to Revisit Small Business Data Rule
April 08, 2025
In light of ongoing legal challenges, the Consumer Financial Protection Bureau (CFPB) said on April 3 that it will reissue the Dodd-Frank-mandated 1071 requirements regarding data that lenders must collect and report on small-business loans.

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