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  • Published on
    FinCEN has permanently exempted U.S. companies and U.S. persons from beneficial ownership reporting and will delete what was already collected. That is real relief for millions of small businesses, and it arrived by regulation rather than by statute — which means the same authority that switched the database off can switch it back on.
  • Published on
    Roughly two trillion dollars of commercial mortgage debt comes due over the next three years, and the industry has read that number as a demand story—borrowers will need capital, and capital will come. In the healthcare corner of the market, the scarce input is not money. It is eligibility, and eligibility is established in documents long before anyone reaches a closing table.
  • Published on
    The intercreditor agreement between a HUD-insured mortgage lender and an accounts receivable lender does not allocate priority among competing claims to the same collateral. The two collateral pools do not overlap. What the document actually does — coordinate two structurally separated lenders around a single going concern — is a different kind of work, and most of the negotiation lives in places a traditional intercreditor analysis would not look.