Krystyna Blakeslee

Krystyna M. Blakeslee focuses her practice on finance and real estate matters. Prior to joining Dechert, Ms. Blakeslee served as a law clerk for the Honorable Alan H. W. Shiff of the U.S. Bankruptcy Court in Bridgeport, CT (2009-2010). She also previously served as a sergeant in the U.S. Marine Corps and was a Dechert summer associate in 2008.

Firm/Organization: Dechert LLP

Blogs: Crunched Credit

Latest Articles

Crunched Credit

HVCRE ADC Update: Regulators Propose Eliminating Exemption for Land Development Loans

By Krystyna Blakeslee & Gina Leahey

October 23, 2019

Just when you thought the regulators had forgotten about HVCRE ADC, they issued a new notice of proposed rulemaking like they were Beyoncé surprise-dropping a new album. And then…they disappeared again! We were waiting for more news before alerting our readers but nothing has come to date. To bring those not in the HVCRE ADC-hive up to speed, the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) reformed the capital rule…

Crunched Credit

Proposed Rule Regarding HVCRE ADC Open for Comment

By Krystyna Blakeslee & Gina Leahey

September 28, 2018

Are you ready? The proposed rule regarding HVCRE ADC has been published in the Federal Register today and is open for comment. You know the drill, comments are due in 60 days (by November 27, 2018). Give us a ring for more background on HVCRE ADC and the proposed rule. We’re always happy to discuss the questions posed by the regulators and consider potential responses. And be sure to check in to Crunched Credit in…

Crunched Credit

Are you there FDIC, OCC and Fed Res? It’s us, Crunched Credit: Regulators Request Feedback on HVCRE ADC

By Krystyna Blakeslee & Gina Leahey

September 25, 2018

On September 18, 2018, the Federal Reserve, FDIC and OCC released a Notice of Proposed Rulemaking (NPR) regarding HVCRE. The good news is that the stated intent is not to alter any of the improvements made by EGRRCPA , instead the agencies describe the proposed rulemaking as conforming the regulatory capital rule to the new statutory definition of HVCRE ADC and providing interpretations of certain terms consistent with their usage in other regulations. This is…

Crunched Credit

HVCRE (The Reformed Loan): Musings and Next Steps

By Krystyna Blakeslee & Gina Leahey

September 17, 2018

Since my last post, the Economic Growth, Regulatory Relief, and Consumer Protection Act (which some are referring to as EGRRCPA – oof.) was signed into law by President Trump on May 24th. Section 214, titled, “Promoting Construction and Development on Main Street,” amends the Federal Deposit Insurance Act to clarify what loans are subject to HVCRE, when loans are measured for HVCRE exposure and what we call loans subject to HVCRE (spoiler alert: it’s not…

Crunched Credit

“Pop the Champagne but Don’t Get Too Drunk”: HVCRE Reform Passes the House

By Krystyna Blakeslee & Gina Leahey

May 22, 2018

When House Speaker Paul Ryan announced earlier this month that the House would vote on S.2155, I wasn’t holding my breath (you know you’re on your last lame duck leg when a “senior GOP lawmaker” says you’ve “run out of juice”). Miracles do happen AND sometimes I love to be wrong (but – shh…don’t tell my husband): In the spirit of deal making, the House just passed S. 2155 (the Economic Growth, Regulatory Relief,…

Crunched Credit

The Day I (Almost) Met Mark Zuckerberg

By Krystyna Blakeslee & Gina Leahey

April 12, 2018

It’s day 2 of Mark Zuckerberg’s Congressional debut and I still have yet to catch a glimpse of him or his entourage. But – I have had the opportunity, with some fellow industry players, CREFC staff and members of the CREFC-HVCRE Working Group, to meet and speak with members of the House Financial Services Committee (Andy Barr and Trey Hollingsworth), Senate Banking Committee staff and regulators from the FDIC, OCC and the Fed. The…

Crunched Credit

No “Fake News” Here – Just the Facts on HVCRE

By Krystyna Blakeslee & Gina Leahey

March 16, 2018

In case you’ve been too busy sifting through fake news to follow efforts to reform the High Volatility Commercial Real Estate (HVCRE) regulations that affect acquisition, development or construction (ADC) loans, here’s where we are and where we think we are going.…

Crunched Credit

HVCRE Reform is HOT HOT HOT: Pittenger Bill Progresses to Senate

By Krystyna Blakeslee & Gina Leahey

November 10, 2017

Add HVCRE reform to the list of things that have bi-partisan support (currently on the list: flag pins and banning the use of Twitter in the White House). On Tuesday, the House passed (with bi-partisan support…which should bolster its chances of passing in the Senate) H.R.2148 – Clarifying Commercial Real Estate Loans, otherwise known as the Pittenger Bill. As we covered in June, the Pittenger Bill aims to address the main shortcomings of…

Crunched Credit

Proposed Changes to HVCRE Open for Comment

By Krystyna Blakeslee & Gina Leahey

October 27, 2017

At long last (at least for those of us who have been checking the Federal Register daily), the proposed HVADC rule has been published in the Federal Register and is open for comment. The public (that’s us!) has 60 days to comment – so all comments are due by December 26, 2017 (Ho ho ho!). Give us a ring if you want to discuss potential issues, pitfalls, comments, or recommendations (or even something more mundane…

Crunched Credit

Yakety Yak – Talk Back: Regulators Respond to HVCRE Complaints

By Krystyna Blakeslee & Gina Leahey

October 20, 2017

On September 27, 2017, the Federal Reserve, FDIC and OCC released a Notice of Proposed Rulemaking (NPR) that they describe as simplifying compliance with certain aspects of the agencies’ risk based capital (RBC) rules to, among other things, replace the standardized approach’s (SA) treatment of HVCRE loans with a simpler treatment for most acquisition, development or construction (ADC) loans called high volatility acquisition, development or construction (HVADC). Spoiler alert: it just replaces vague and confusing…

Krystyna Blakeslee

HVCRE ADC Update: Regulators Propose Eliminating Exemption for Land Development Loans

Proposed Rule Regarding HVCRE ADC Open for Comment

Are you there FDIC, OCC and Fed Res? It’s us, Crunched Credit: Regulators Request Feedback on HVCRE ADC

HVCRE (The Reformed Loan): Musings and Next Steps

“Pop the Champagne but Don’t Get Too Drunk”: HVCRE Reform Passes the House

The Day I (Almost) Met Mark Zuckerberg

No “Fake News” Here – Just the Facts on HVCRE

HVCRE Reform is HOT HOT HOT: Pittenger Bill Progresses to Senate

Proposed Changes to HVCRE Open for Comment

Yakety Yak – Talk Back: Regulators Respond to HVCRE Complaints

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