"Concerning construction lending; let’s not forget Basel III and its High Volatility Commercial Real Estate Act (HVCRE), which requires lenders to hold in their capital reserves 150% of the construction loan amount being funded. HVCRE was implemented last year (2015) for the “Big Banks” Worldwide. This year (2016) HVCRE will be implemented for the local and regional banks. Unless the borrowers are already preferred clients of the commercial banks who do CRE lending the borrowers will not be able to qualify for a construction loan.
This is why the private and hard money lenders are taking over this space, for they are not regulated by Dodd-Frank nor Basel III. Conclusion: Borrowers need to underwrite their developments with higher interest and points these lenders charge."