Davis Polk partner David Portilla was quoted in 9fin discussing the relaxed underwriting guidelines from the OCC and the FDIC. The article noted that the agencies released a joint statement rescinding a 2013 ruleset, which allows banks to underwrite loans to riskier companies that had previously been required to borrow from private markets.

While the piece pointed out that this change could increase competition between banks and private credit firms, David said, “It’s not a zero-sum between banks and private credit. I think to the extent banks can step in and provide credit in those cases, and so can private credit funds, borrowers will have a choice between different lenders depending on what makes the most sense for a particular transaction.”

“Agencies pull U.S. LevLoan guidance — what’s next?” 9fin (December 8, 2025) (subscription required)

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