Certain of our domestic and foreign subsidiaries are also subject to resolution and recovery planning requirements in the jurisdictions in which they operate. For example, MSBNA must submit to the FDIC an annual resolution plan that describes MSBNAs strategy for a rapid and orderly resolution in the event of material financial distress or failure of MSBNA. In September 2016, the OCC issued final guidelines that establish enforceable standards for recovery planning by national banks and certain other institutions with total consolidated assets of $50billion or more, calculated on a rolling four-quarter average basis, including MSBNA. The guidelines were effective on January1, 2017, and MSBNA must be in compliance by January1, 2018.
Certain of our domestic and foreign subsidiaries are also subject to resolution and recovery planning requirements in the jurisdictions in which they operate. For example, MSBNA must submit to the FDIC an annual resolution plan that describes MSBNAs strategy for a rapid and orderly resolution in the event of material financial distress or failure of MSBNA. In September 2016, the OCC issued final guidelines that establish enforceable standards for recovery planning by national banks and certain other institutions with total consolidated assets of $50billion or more, calculated on a rolling four-quarter average basis, including MSBNA and MSPBNA. The guidelines were effective on January1, 2017, and applied to MSBNA as of January1, 2018. MSPBNA must be in compliance by October1, 2018.
In September 2016, the OCC issued final guidelines that establish enforceable standards for recovery planning by national banks and certain other institutions with total consolidated assets of $50 billion or more, calculated on a rolling four-quarter average basis, including MSBNA. The guidelines are effective on January 1, 2017, and MSBNA must be in compliance by January 1, 2018.
(2)The mortgage loan secured by the mortgaged property identified on Annex A-1 to the Preliminary Prospectus as Pentagon Center, representing approximately 5.5% of the aggregate principal balance of the pool of mortgage loans as of the cut-off date, is part of a whole loan that was co-originated by Goldman Sachs Mortgage Company (“GSMC”) and Morgan Stanley Bank, N.A. (“MSBNA”). The mortgage loan, consisting of Note A-4, Note A-5 and Note A-6, is expected to be acquired by MSMCH prior to the closing date, and will be sold by MSMCH into the BANK 2017-BNK4 securitization. The mortgage loan secured by the mortgaged property identified on Annex A-1 to the Preliminary Prospectus as Merrill Lynch Drive, representing approximately 4.1% of the aggregate principal balance of the pool of mortgage loans as of the cut-off date, is part of a whole loan that was co-originated by Barclays and MSBNA. The mortgage loan, consisting of Note A-3, is expected to be acquired by MSMCH prior to the closing date, and will be sold by MSMCH into the BANK 2017-BNK4 securitization.