Photo of Alexandra Ciganer

Alexa is counsel in the Technology and Venture Lending practice in Los Angeles, Orange County, and San Francisco. She has a broad range of experience representing commercial banks, noninstitutional lenders, and private and public corporate borrowers, in secured and unsecured lending transactions with an emphasis on bilateral and syndicated capital call lines of credit and subscription based credit facilities, asset based loans, life science lending transactions, energy resource technology credit facilities, acquisition financing arrangements, and equipment financings. These transactions involve public and private technology companies, venture capital and private equity funds, life science and biopharmaceutical companies, and high-net-worth individuals.

On December 5, 2025, the Office of the Comptroller of the Currency (OCC) issued OCC Bulletin 2025-45, “Commercial Lending: Venture Loans to Companies in an Early, Expansion, or Late Stage of Corporate Development,” which rescinds OCC Bulletin 2023-34, “Commercial Lending: Venture Loans to Companies in an Early, Expansion, or Late Stage of Corporate Development.” The OCC’s message in issuing the new bulletin to replace the prior bulletin is straightforward: the agency does not want to discourage prudent venture lending. At the same time, it expects banks to recognize that venture loans carry materially higher default risk than conventional commercial loans and to manage that risk through disciplined underwriting, realistic risk ratings, and appropriate reserves.[1]